A new trend – Alamos tax disclosure excludes CRICs

Alamos (which has only foreign mining properties) has structured its offer for Aurizon (which on an aggregate basis provides 50% share consideration (Alamos shares) and 50% cash consideration) so as to ensure that the s. 85.1 rollover is not available except for shareholders who receive only Alamos shares.  The tax disclosure states that it does not apply to corporations resident in Canada who are non-resident controlled for purposes of the foreign affiliate dumping rules.

Neal Armstrong.  Summary of Alamos Circular under Unsolicited Bids.