Resident Holder definition

Resident Holder means a Holder who, for the purposes of the Tax Act and at all relevant times, is or is deemed to be a resident of Canada.

Resident Holder means a Holder who, for the purposes of the Tax Act and at all relevant times, is or is deemed to be a resident of Canada. “RESP” has the meaning given to it under Item 3.D “Risk Factors — Risks Relating to Taxation — Canada”.

Resident Holder means a beneficial holder of the Notes who, for the purposes of the Tax Act and any applicable income tax convention, at all relevant times, is or is deemed to be resident in Canada;

Examples of Resident Holder in a sentence

• If Notes have been owned for at least 12 months prior to the sale (excluding the days of acquisition and disposal), a Resident Holder (other than a company) may be entitled to receive CGT discount treatment in respect of any gain arising on disposal of Notes, such that a percentage of the gain is not included in assessable income.

• The Resident Holder will recognize a capital gain (or a capital loss) equal to the amount by which such proceeds of disposition are greater (or less) than the aggregate of the adjusted cost base of the Convertible Debentures to the Resident Holder and any reasonable costs of disposition.

• A Resident Holder will be required to include all such interest in computing its income under the Tax Act for the taxation year in which the Date of Conversion occurs, to the extent such amount has not otherwise been included in income in a preceding taxation year.

• Subject to and in accordance with the provisions of the Tax Act, a Resident Holder is required to deduct one-half of the amount of any capital loss (an “allowable capital loss”) realized in a taxation year from taxable capital gains realized by the Resident Holder in the year.

• As a result, the Resident Holder will generally realize a capital gain (or a capital loss) to the extent that such proceeds of disposition exceed (or are less than) the aggregate of the Resident Holder’s adjusted cost base, calculated immediately before the time of disposition, of the respective Ordinary Shares being disposed and any reasonable costs of disposition.

More Definitions of Resident Holder

Resident Holder means a Holder who, at all relevant times, for purposes of the Canadian Tax Act and any applicable income tax treaty or convention, is or is deemed to be a resident of Canada;

Resident Holder means a Holder who, at all relevant times, for purposes of the Tax Act and any applicable income tax treaty or convention, is resident in Canada;

Resident Holder means a Holder who, for purposes of the Tax Act and at all relevant times, is resident or is deemed to be resident in Canada under the Tax Act;

Resident Holder means a Shareholder who is a Resident;

Resident Holder means a Holder that, at all relevant times for the purposes of the Tax Act, is or is deemed to be resident in Canada. "Restructuring Transactions" means, collectively, the Rights Offering and the Debt Restructuring.

Resident Holder means a Spartan Shareholder who is resident or deemed to be resident in Canada for purposes of the ITA and any applicable income tax treaty.

Resident Holder means a Holder who, for purposes of the ITA and any applicable income taxconvention, is or is deemed to be a resident of Canada at all relevant times;