Income and gains arising from dispositions of excluded property other than foreign affiliate
shares to specified purchasers will be suspended (not included in exempt or taxable earnings of an affiliate
) until the property is no longer owned by the specified purchaser or the purchaser ceases to meet the definition of specified purchaser.
In addition to requiring that the transaction be on market terms, section 23B specifically prohibits a bank from purchasing any security for which a section 20 affiliate
is a principal underwriter during the existence of the underwriting or selling syndicate unless such a purchase has been approved by a majority of the bank's board of directors who are not officers of any bank or any affiliate
Referrals to the affiliate
typically take one of two forms.
Informal discussions with Finance officials suggest that this rule is likely to be modified to exempt dispositions of shares of another affiliate
provided that the disposition is subject to tax in the holding company's jurisdiction.
shoppers are four percent more likely to have children in their household than the typical Internet shopper.
To establish a Komen Affiliate
a dedicated group of breast cancer activists, representative of a cross-section of the proposed Affiliate
service area, must submit a letter of intent and subsequent application and community needs assessment to Komen headquarters.
In some cases, the control test in subsection 95(1) will impose the higher reporting burden on Canadian taxpayers even where no one Canadian taxpayer-shareholder or group of Canadian taxpayer-shareholders can actually or legally compel the foreign affiliate
to supply the requisite information.
Compare performance metrics that impact an affiliate
program across groups of comparable merchants within the 63 merchants studied
Form T1134 and the draft reporting requirements seemingly require a Canadian taxpayer to report separately every asset disposition by a foreign affiliate
that gives rise to capital gains, regardless whether the gain arises from excluded or non-excluded property.
As a unique super affiliate
, Second Bite works on a performance basis, recovering revenue in turn for commissions on each sale.
The requirement that the income be from either the only or principal business of an affiliate
in order to qualify for the investment business exceptions will discourage multinational groups from reducing the number of foreign affiliates
, despite the groups' desires to right-size corporate structures and reduce substantial administrative costs.
Software product offerings spell tremendous opportunity for affiliates
," said Todd Crawford, Digital River's vice president of affiliate
sales and business development.
s service department assists with managing the implementation of the program, including affiliate
communications and payments to affiliates
Nate has played a key role in maintaining strong relationships with our Affiliate
partners and identifying opportunities to develop and grow their businesses.
of Sun Capital, will be confirmed as the stalking horse bidder to acquire, through a Section 363 Bankruptcy Code sale process, substantially all of the assets of The Rowe Companies, Rowe Furniture, Inc.