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Unformatted text preview: isproportionate class of shares” is defined in article xxix a(5)(c) to mean a class of shares of a company that is resident in one state that entitles the holder to a disproportionately higher participation in the earnings generated in the other state through dividends, redemption payments, or otherwise. The technical explanation confirms that this concept is intended to include tracking shares. The inclusion of the term “disproportionate class of shares” is intended to prevent a company from being established with primarily us and Canadian shareholders but also with a special class of shares that redirects income that has otherwise been entitled to treaty benefits to residents of a third country. article X XIX a(2)( d ): subsidiary o f a Public Company Test article xxix a(2)(d) provides that a company or trust is a qualifying person if five or fewer persons, each of which is a company or trust that is a qualifying person under article xxix a(2)(c), own directly or indirectly more than 50 percent of the aggregate vote and the value of the shares and more than 50 percent of the vote and value of each...
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