Intrepid -- summary under Capital distributions

Overview

Intrepid Mines, an Australian company, is proposing to distribute approximately 87% of its assets in cash as a capital distribution.

Company

The Company is listed on the ASX and the TSX and which received US$80 million in settlement of all disputes surrounding ownership of the Tujuh Bukit copper/gold project in Indonesia.

Globex -- summary under Butterfly spin-offs

TSX-listed Globex is proposing a spin-off to its shareholders by way of butterfly reorganization of CIM, a newly-incorporated subsidiary that is proposed to be listed on the TSX-V and that will hold various mining and exploration properties in the Chibougamu mining camp.

Butterfly steps

The butterfly reorganization is implemented through the following steps occurring under a Quebec plan of arrangement:

Calloway OSC order -- summary under Subtrust Elimination.

Current structure

Calloway is an open-end REIT, with a market cap of $2.8B, whose units trade on the TSX. It owns all the units of Calloway Holdings Trust ("Sub Trust") which, in turn, holds Class A units of three subsidiary LPs. Third parties also hold units of the three LPs including exchangeable units.

Transaction overview

In order to effectively wind-up Sub Trust on a rollover basis:

Pages

Subscribe to Tax Interpretations RSS