税务信息
税务信息
股息税收抵免
威尼斯电玩城手游公司和横加管道有限公司, 就所得税法(加拿大)而言, 以及任何类似的省或地区立法, each designate that all dividends paid by TC Energy Corporation or TransCanada PipeLines Limited respectively, 12月后. 31, 2005, to be "eligible dividends" unless otherwise notified by TC Energy Corporation or TransCanada PipeLines Limited. 向加拿大居民支付的合格股息有权享受增强的股息税收抵免.
非居民投资者
股息 paid by TC Energy to shareholders outside Canada are subject to Canadian non-resident withholding tax. The general rate is 15 per cent for the investors resident in the United States and other countries where Canadian tax treaties apply.
有效的简. 1, 2018, the US Internal Revenue Service (IRS) regulations require certain foreign payers of dividends or interest to US persons (including resident aliens) to withhold and pay to the IRS 24 per cent (reduced from 31 per cent) of such payments ("Backup Withholding"). This Backup Withholding is in addition to the non-resident tax rate of 15 per cent required under Canadian law. Residents of non-treaty countries are subject under Canadian law to a 25 per cent withholding tax on dividends.
2024年10月液体管道业务分拆
10月1日, 2024, TC Energy Corporation announced the completion of the spin-off of its Liquids Pipelines 业务 into South Bow Corporation. TC Energy shareholders retained their interest in TC Energy common shares and received a pro rata allocation of South Bow common shares. TC Energy普通股的每位持有人一般获得0.90美元.在分配记录日,每持有一股TC Energy普通股,对应2股South Bow普通股
加拿大税务信息
Resident shareholders should not realize a capital gain or capital loss as a result of the distribution. The adjusted cost base in TC Energy shares prior to the distribution is allocated based on the fair market values of TC Energy and South Bow immediately after the distribution. The allocation has been determined to be 91% to TC Energy common shares and 9% to South Bow common shares.
U.S. 税务信息
The distribution should qualify as a tax-free distribution under section 355(a) of the Internal Revenue Code. U.S. holders of TC Energy common shares should recognize no gain or loss upon receipt of South Bow common shares except with respect to any cash received in lieu of fractional South Bow common shares. The tax basis in TC Energy common shares should be allocated between TC Energy common shares and South Bow common shares, 包括任何被视为收到的零碎股份, 按其在分拆完成之日的相对公平市场价值的比例. 而你.S. federal income tax law does not specifically prescribe how shareholders should determine the fair market values for this purpose, one reasonable approach would allocate the pre-spin-off aggregate tax basis in TC Energy common shares (i) 91% to TC Energy common shares and (ii) 9% to South Bow common shares.
1998年TransCanada和Nova合并和税务信息
- 1998年美国股东所得税资料 (14kb, pdf)
(包括普通股息收入, 降低威尼斯电玩城手游普通股的税基, 资本利得信息.) - 联合管理资料通告(5/98) (1mb, PDF)(有关1998年7月2日合并的信息.)
Nova和TC Energy(当时名为TransCanada)致加拿大股东的联名信
回复:1998年7月2日确定股份的公平市场价值
As was stated in the Canadian income tax section set out on pages 66 - 70 of the 联合管理资料通告 dated May 19, 1998年(“联合资料通告”), the determination of the fair market value of certain shares is relevant to the shareholders of NOVA and TransCanada in determining the Canadian income tax consequences of the transactions described in the Plan of Agreement (the "Plan"), 于7月2日生效, 1998.
All capitalized terms not otherwise defined herein have the same meanings as set out in the Joint Information Circular. Revenue Canada may accept a number of different approaches in valuing shares of a public company at a particular time.
供参考, NOVA and TransCanada are presently planning for purposes of their respective Canadian tax filings to determine the fair market value of the publicly traded shares by reference to the ten day weighted average prices as transacted on The Toronto Stock Exchange.
基于使用十天加权平均价格得出的估值方法, 公平市场价值为:
NOVA普通股(合并前) | $16.90 |
横加公司普通股 | $32.50 |
NOVA Common Share (post-merger) (referred to in the Joint Information Circular as a NOVA Chemicals Common Share) | $27.85 |
使用这种评估方法,
- 出售NOVA普通股的收益为16美元.90;
- NOVA普通股股东收到TransCanada普通股的初始成本为32美元.50;
- For purposes of calculating the cost of a TransCanada common share (referred to in the Joint Information Circular as an EnergyCo. 普通股)在计划生效后立即支付5美元.57 ( .2 of $27.85 to reflect the 1 for 5 share consolidation) must be deducted from the adjusted cost base otherwise determined of each 横加公司普通股;
- The cost of a NOVA common share (post-merger) (referred to in the Joint Information Circular as a NOVA Chemicals Common Share) was $27.85.
The above information is being provided in light of numerous requests received by both companies from Canadian shareholders. This letter is not intended to be a substitute for the description of tax consequences in the Joint Information Circular and should not be construed to be legal, 业务, 向任何特定股东提供税务或估值建议. 相应的, shareholders should consult their own advisors as to the tax consequences to them of the Plan in their circumstances, 特别是如果股东希望考虑采用不同的估值方法.
除上述内容外, NOVA will be sending its shareholders T5 income tax reporting slips for purposes of reporting the deemed dividend arising on the cash payment in lieu of (and on the cancellation of) an interest in a fractional share as described on page 68 of the Joint Information Circular.
如果你对上述任何内容有任何疑问, 请致电1-800-361-6522与威尼斯电玩城手游联系.
Nova和威尼斯电玩城手游(当时名为TransCanada)致美国股东的联名信
回复:1998年7月2日确定股份的公平市场价值
The plan of Arrangement (the "Plan") involving NOVA Corporation ("NOVA") and TransCanada PipeLines Limited ("TransCanada") described in the 联合管理资料通告 dated May 19, 一九九八年(“联合资料通告”)已于七月二日生效, 一九九八年(“生效日期”). 如美国所得税部分所述, 载于联合资料通告第70至75页, the fair market value of a common share of NOVA on the Effective Date after consummation of the Plan (a "NOVA common share" which is referred to in the Joint Information Circular as a NOVA Chemicals Common Share) and the fair market value of a common share of TransCanada without giving effect to the distribution of the NOVA Common Shares (a "横加公司普通股") is relevant to shareholders of TransCanada and NOVA for purposes of determining certain United States federal income tax consequences to them of the Plan. 这封信的目的是提供有关公平市场价值估计的信息.
All capitalized terms not otherwise defined herein have the same meanings as set out in the Joint Information Circular.
The Internal Revenue Service may accept different approaches in valuing shares of a publicly-traded company at a particular time.
根据与美国税务顾问的讨论, we believe that it would be reasonable to use the following amounts (which are expressed in United States dollars) as estimates of fair market value:
横加公司普通股 | $22.23 |
NOVA普通股(在联合资料通告中称为NOVA化学品普通股) | $20.89 |
The estimated fair market value of a 横加公司普通股 was derived from the simple average of the high and low trading prices on the Toronto Stock Exchange on July 2, 1998. The estimated fair market value of a NOVA普通股(在联合资料通告中称为NOVA化学品普通股) was derived from the opening trading price on the Toronto Stock Exchange on July 3, 1998. These amounts were converted to United States dollars based on the mid-day exchange rate in effect on the particular date.
利用这些估计值,
- 获得NOVA普通股的对价的公平市场价值为11美元.56 ( .52 x $22.23);
- NOVA普通股股东收到的TransCanada普通股的初始计税基础, 在因NOVA普通股的分配而对该税基进行任何调整之前, 是22美元.23;
- The initial tax basis in a NOVA普通股(在联合资料通告中称为NOVA化学品普通股) received by NOVA and TransCanada common shareholders was $20.89.
TransCanada intends to report to United States shareholders in February 1999 the portion of the fair market value of a NOVA普通股(在联合资料通告中称为NOVA化学品普通股) that should be treated as a dividend for US federal income tax purposes.
The above information is being provided in light of numerous requests received by both companies from United States shareholders. This letter is not intended to be a substitute for the description of tax consequences in the Joint Information Circular and should not be construed to be legal, 业务, 向任何特定股东提供税务或估值建议. We believe that the use of the trading prices set forth above is a reasonable approach to estimate the fair market values of a 横加公司普通股 and a NOVA Common Share for purposes of determining certain United States federal income tax consequences of the Plan; however, 如上所述, 为此目的可采用其他办法. 相应的, shareholders should review the United States tax section in the Joint Information Circular and should consult their own advisors as to the tax consequences to them of the Plan in their particular circumstances, 特别是如果股东希望考虑采用不同的估值方法.
除上述内容外, NOVA will be sending its United States shareholders NR4 supplementary income tax reporting slips for purposes of reporting for Canadian federal income tax purposes the deemed dividend and related non-resident withholding tax arising on the cash payment in lieu of (and on the cancellation of) an interest in a fractional share as described on page 70 of the Joint Information Circular.
如果你对上述任何内容有任何疑问, 请致电1-800-361-6522与威尼斯电玩城手游联系.