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Investor Presentaiton

CORPORATE LAW BY ALAIN RANGER BRAZIL - CANADA COMPARATIVE LAW the purpose of carrying on a single enterprise or specific venture. Joint ventures take several forms. They can be set up through a separate corporation, a general or limited partnership, or the joint venturers can simply jointly own business assets. Joint ventures between Canadian and foreign companies are an excellent vehicle for combining the strengths of the participating firms, while reducing the risk of taking on new markets. The joint venturers are liable for the tax on their income earned as participants in the joint venture. (D) Franchises A franchise is a business relationship in which a franchisee contracts for the right to sell proprietary products or services using business names, styles and methods developed by the franchisor. The franchisee generally agrees to comply with performance standards set by the franchisor. In return, the franchisee normally pays an up-front fee as well as ongoing royalties. A simple franchise agreement typically gives the franchisee the right to operate a single outlet at a specified location. A master franchise agreement generally provides for multiple outlets within a specified area. 2. TAX SYSTEM 2.1 General Aspects Income tax in Canada is imposed by the federal, provincial and territorial governments. Subject to certain tax treaty concessions, non-residents of Canada are generally subject to Canadian taxation on Canadian source income, such as income from a business carried on in Canada, income from office or employment in Canada and capital gains on the disposition of property known as "taxable Canadian property", which generally includes: . Real property situated in Canada; Assets used in a business carried on in Canada; A share of a private corporation resident in Canada where more than 50% of the fair market value of the share is derived (or was derived at any time in the previous 60-month period) from real property in Canada, Canadian resource properties, timber resource properties and options in respect of any such property; A share of a public corporation (or mutual fund trust) where (i) the holder holds more than 25% of the issued shares and (ii) more than 50% 15
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