4 unchanged sentences
Since its inception, ITH has not paid any dividends.
−Removed: ITH has no present intention of paying any dividends, as it anticipates that all available funds will be invested to finance the growth of its business.
+Added: ITH has no present intention of paying any dividends, as it anticipates that all available funds will be invested to finance development of the Livengood Gold Project.
The Board will determine if and when dividends should be declared and paid in the future after taking into account many factors, including ITH’s financial condition, operating results and anticipated cash needs at the relevant time.
There are no restrictions which prevent ITH from paying dividends.
−Removed: Recent Sales of Unregistered Equity Securities
−Removed: Purchases of Equity Securities by the Issuer and Affiliated Purchasers
Exchange Controls
11 unchanged sentences
Treaty”), the Canadian Tax Act, the regulations thereunder, all specific proposals to amend the Canadian Tax Act and regulations publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof and the Company’s understanding of the administrative policies and assessing practices published in writing by the Canada Revenue Agency prior to the date hereof.
−Removed: This summary assumes that all specific proposals to amend the Canadian Tax Act and regulations will be enacted as currently proposed, does not otherwise take into account any change in law or administrative policy or assessing practice, whether by judicial, governmental,
−Removed: legislative or administrative decision or action, and does not take into account other federal or provincial, territorial or foreign tax consequences, which may vary from the Canadian federal income tax considerations described herein.
+Added: This summary assumes that all specific proposals to amend the Canadian Tax Act and regulations will be enacted as currently proposed, does not otherwise take into account any change in law or administrative policy or assessing practice, whether by judicial, governmental, legislative or administrative decision or action, and does not take into account other federal or provincial, territorial or foreign tax consequences, which may vary from the Canadian federal income tax considerations described herein.
This summary is of a general nature only, is not exhaustive of all Canadian federal income tax considerations, and it is not intended to be, nor should it be construed to be, legal or tax advice to any Non-Resident Holder of common shares and no representation with respect to Canadian federal income tax consequences to any Non-Resident Holder of common shares is made herein.
28 unchanged sentences
This discussion does not purport to be a comprehensive description of all of the U.S.
−Removed: tax considerations that may be relevant to a particular investor’s decision to acquire the common shares, including any state, local or non-U.S.
+Added: tax considerations that may be relevant to a particular investor’s decision to acquire our common shares, including any state, local or non-U.S.
tax consequences of acquiring, owning, and disposing of common shares.
This discussion applies only to those U.S.
−Removed: Holders that hold common shares as capital assets for U.S.
+Added: Holders that hold our common shares as capital assets for U.S.
tax purposes (generally, for investment and not in connection with the carrying on of a trade or business) and does not address all aspects of U.S.
−Removed: federal income tax law that may be relevant to investors that are subject to special or different treatment under U.S.
+Added: federal income tax law that may be relevant to investors that are subject to
+Added: special or different treatment under U.S.
federal income tax law (including, for example, a holder liable for the alternative minimum tax or a holder that actually or constructively owns 10% or more by voting power or value of our common shares).
19 unchanged sentences
If a partnership (including any entity treated as a partnership for U.S.
−Removed: federal income tax purposes) is a beneficial owner of the common shares, the U.S.
+Added: federal income tax purposes) is a beneficial owner of our common shares, the U.S.
tax treatment of a partner in the partnership generally will depend on the status of the partner and the activities of the partnership.
−Removed: A holder of the common shares that is a partnership and partners in such a partnership should consult their own tax advisors about the U.S.
−Removed: federal income tax consequences of acquiring, owning, or disposing of common shares, particularly in light of recent U.S.
+Added: A holder of our common shares that is a partnership and partners in such a partnership should consult their own tax advisors about the U.S.
+Added: federal income tax consequences of acquiring, owning, or disposing of common shares.
Distributions
Subject to the passive foreign investment company rules discussed below, should a distribution be made, a U.S.
−Removed: Holder must include in gross income as dividend income the gross amount of any distribution paid on the common shares (including the amount of any non-U.S.
+Added: Holder must include in gross income as dividend income the gross amount of any distribution paid on our common shares (including the amount of any non-U.S.
taxes withheld from such amount), to the extent such distribution is paid out of current or accumulated earnings and profits (as determined for U.S.
2 unchanged sentences
federal income tax purposes) will first be treated as a non-taxable return of capital to the extent of the U.S.
−Removed: Holder’s basis in the common shares and thereafter as gain from the sale or exchange of common shares.
+Added: Holder’s basis in its common shares and thereafter as gain from the sale or exchange of common shares.
See “Sale, Exchange, or Other Disposition of Common Shares” below.
7 unchanged sentences
Holder, dividends received generally will not be eligible for the dividends-received deduction.
−Removed: Dividends paid on the common shares will generally be treated as foreign source income for U.S.
+Added: Dividends paid on our common shares will generally be treated as foreign source income for U.S.
foreign tax credit purposes.
4 unchanged sentences
Subject to the passive foreign investment company rules discussed below, a U.S.
−Removed: Holder that sells or otherwise disposes of the common shares will recognize capital gain or loss for U.S.
+Added: Holder that sells or otherwise disposes of its common shares will recognize capital gain or loss for U.S.
federal income tax purposes equal to the difference between (i) the U.S.
23 unchanged sentences
Holder’s holding period.
−Removed: Holder that holds common shares while the Company is a PFIC may be subject to increased tax liability upon the sale, exchange, or other disposition of the common shares or upon the receipt of certain distributions, regardless of whether the Company is a PFIC in the year in which such disposition or distribution occurs.
+Added: Holder that holds common shares while the Company is a PFIC may be subject to increased tax liability upon the sale, exchange, or other disposition of its common shares or upon the receipt of certain distributions, regardless of whether the Company is a PFIC in the year in which such disposition or distribution occurs.
These adverse tax consequences include:
1 unchanged sentence
An excess distribution generally is the excess of the amount a PFIC distributes to a shareholder during a taxable year over 125% of the average amount it distributed to the shareholder during the three preceding taxable years or, if shorter, the part of the shareholder’s holding period before the taxable year.
−Removed: Distributions with respect to the common shares during the taxable year to a U.S.
+Added: Distributions with respect to our common shares during the taxable year to a U.S.
Holder that are excess distributions must be allocated rateably to each day of the U.S.
4 unchanged sentences
Holder in that prior year (without offset by any net operating loss for such year) and the tax is subject to an interest charge at the rate applicable to deficiencies in income taxes (the “special interest charge”).
−Removed: The entire amount of any gain realized upon the sale or other disposition of the common shares will be treated as an excess distribution made in the year of sale or other disposition and as a consequence will be treated as ordinary income and, to the extent allocated to years prior to the year of sale or disposition, will be subject to the special interest charge described above.
+Added: The entire amount of any gain realized upon the sale or other disposition of our common shares will be treated as an excess distribution made in the year of sale or other disposition and as a consequence will be treated as ordinary income and, to the extent allocated to years prior to the year of sale or disposition, will be subject to the special interest charge described above.
Special rules apply for calculating the amount of the foreign tax credit with respect to excess distributions by a PFIC.
47 unchanged sentences
Holders should consult their own tax advisors regarding the PFIC rules and how they may affect the U.S.
−Removed: federal income tax consequences of the acquisition, ownership, and disposition of common shares in the event the Company is a PFIC at any time during the holding period for such common shares.
+Added: federal income tax consequences of the acquisition, ownership, and disposition of our common shares in the event the Company is a PFIC at any time during the holding period for such common shares.
Holder that is an individual or estate, or a trust that does not fall into a special class of trusts that is exempt from such tax, will be subject to a 3.8% tax on the lesser of (1) the U.S.
2 unchanged sentences
A holder’s net investment income will generally include dividend income and net gains from the disposition of common shares, unless such dividends or net gains are derived in the ordinary course of the conduct of a trade or business (other than a trade or business that consists of certain passive or trading activities).
−Removed: Holders are urged to consult their own tax advisors regarding the applicability of the Medicare tax in respect of their investment in the common shares.
+Added: Holders are urged to consult their own tax advisors regarding the applicability of the Medicare tax in respect of their investment in our common shares.
Disclosure Requirements for Specified Foreign Financial Assets
4 unchanged sentences
Substantial penalties may be imposed, and the period of limitations on assessment and collection of U.S.
−Removed: federal income taxes may be extended, in the event of a failure to comply with this reporting and filing requirement.
+Added: federal income
+Added: taxes may be extended, in the event of a failure to comply with this reporting and filing requirement.
Holders should consult their own tax advisors as to the possible application to them of these requirements.
32 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.