税务信息

税务信息

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 威尼斯电玩城手游 Corporation or TransCanada PipeLines Limited respectively, 12月后. 31, 2005, to be "eligible dividends" unless otherwise notified by 威尼斯电玩城手游 Corporation or TransCanada PipeLines Limited. An eligible dividend paid to a Canadian resident is entitled to the enhanced dividend tax credit.

股息 paid by 威尼斯电玩城手游 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.

• 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.)

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.

Based on a valuation approach derived from the use of ten day weighted average prices, 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，

1. 出售NOVA普通股的收益为16美元.90;
2. The cost of a 横加公司普通股 received by a NOVA Common Shareholder was initially $32.50;
3. 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;
4. 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, particularly if a shareholder wishes to consider adopting a different valuation approach.

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NOVA 1-800-522-1721或TransCanada 1-800-361-6522.

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. The purpose of this letter is to provide information regarding estimates of such fair market values.

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 Common Share (referred to in the Joint Information Circular as a NOVA Chemicals Common Share)	$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 Common Share (referred to in the Joint Information Circular as a NOVA Chemicals Common Share) 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，

1. The fair market value of the consideration received for a NOVA Common Share was $11.56 ( .52 x $22.23);
2. The initial tax basis in a 横加公司普通股 received by a NOVA Common Shareholder, prior to any adjustment to such tax basis as a result of the distribution of the NOVA Common Shares, 是22美元.23;
3. The initial tax basis in a NOVA Common Share (referred to in the Joint Information Circular as a NOVA Chemicals Common Share) 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 Common Share (referred to in the Joint Information Circular as a NOVA Chemicals Common Share) 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, particularly if a shareholder wishes to consider adopting a different valuation approach.

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, 请联系NOVA 1-800-522-1721或TransCanada 1-800-361-6522.