Examples of ULC Notes in a sentence
No IRS ruling has been requested as to whether the Carbon ULC Notes or Existing Securityholder Notes should be treated for U.S. federal income tax purposes as debt.
CORPORATE CAPITALIZATION ___________________________________ Note: Total existing debt excludes all ULC Notes due to Canada deconsolidation in December 2005.
Cash distributions to Unitholders are not guaranteed and, subject to required regulatory approvals, the Fund may in certain circumstances distribute to Unitholders additional Units in lieu of cash distributions on account of income, or securities of Carbon Canada, Carbon ULC Notes or other property in lieu of cash on a redemption of Units or on termination of the Fund.
The previous precept had no provision for any of these activities and did not cover basic costs incurred each year.
There is a risk that the Carbon ULC Notes and/or Existing Securityholder Notes could be treated for U.S. federal income tax purposes as equity rather than debt, in which case the otherwise deductible interest on the Carbon ULC Notes and/or Existing Securityholder Notes would be treated as non-deductible distributions.
The Fund Note Subscription Price shall be paid at the Closing Time by, or on behalf of, the Fund by delivery of a bank draft or a certified cheque payable to, or to the order of, Custom Direct ULC, or as may be otherwise directed by Custom Direct ULC in writing, against delivery by Custom Direct ULC of the $55,076,493.00 principal amount Custom Direct ULC Notes registered in the name of the Fund.
The percent of the interest owing on the Existing Securityholder Notes and the Carbon ULC Notes, respectively, that is paid in respect of a period will be equal.
With respect to the Carbon ULC Notes, to the extent such distributions are treated as dividends, they would be subject to U.S. federal withholding tax at a rate of 30% (subject to reduction under an applicable income tax treaty).
There is hereby authorized to be issued under the Original Indenture, as supplemented by the First Supplemental Indenture, the New Notes, the terms and conditions of which are the same in all respects as the Original Notes, except for the issue date and the issue price, and which will be consolidated to form a single series and be fully fungible with the Original Notes and designated as “4.346% Brookfield Property Finance ULC Notes due 2023”.
Also, in such case, the "portfolio interest" exemption may not be available and interest paid with respect to the Carbon ULC Notes may be subject to U.S. federal withholding tax at a rate of 30% (subject to reduction under an applicable income tax treaty).