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For the purpose of determining the Agreed Amount of the depreciable property of a prescribed class, the reference to "... the undepreciated capital cost to the taxpayer of all property of that class immediately before the disposition... ...

Investors may choose to finance up to approximately XXXXXXXXXX % of their investment in Units by way of a Unit Loan from the Unit Lender. ...

In either case, on a diluted basis, the public or such party or parties will own less than 50 % of the issued and outstanding voting shares in the capital of PublicCo. ...

To the best of the knowledge of the directors and senior officers of Canco, as of the date hereof, no person or group of related persons beneficially owns, directly or indirectly, more than ten percent of the issued and outstanding common shares of Canco, except XXXXXXXXXX who holds approximately XXXXXXXXXX % of Canco's issued common shares either directly or through XXXXXXXXXX ("Xco") a private company which is wholly-owned by him. 8. ...

XXXXXXXXXX owns XXXXXXXXXX units of XXXXXXXXXX, representing approximately XXXXXXXXXX % of the XXXXXXXXXX issued and outstanding units of XXXXXXXXXX, In XXXXXXXXXX announced its intention to commence normal course purchases of units of XXXXXXXXXX through the facilities of XXXXXXXXXX. ...

The share capital of each new corporation will consist of: (a) a class of common shares; and (b) a class of special shares designated as Class A special shares with the following share attributes: (i) voting; (ii) redeemable and retractable at a redemption amount ("Redemption Amount") of $XXXXXXXXXX per share; (iii)for the purpose of subsection 191(4) of the Act, the terms and conditions of the Class A special shares to be issued as described in paragraph 15 below will, at the time of their issue, specify $XXXXXXXXXX per share as the amount for which the share is to be redeemed, acquired or cancelled which amount will be equal to the fair market value of the property received by the particular new corporation as consideration for such share; (iv) entitled to an annual non-cumulative dividend, not to exceed xxxxxxxxxx % per annum of their Redemption Amount, to be paid at the discretion of the directors of the particular new corporation; and (v) the stated capital of these special shares will be determined on the date of issuance. 6. ...

As at XXXXXXXXXX, the following Shareholder Advances and Shareholder Loans were outstanding – a positive amount represents an amount due from the corporation to the shareholder: Mr. ...

On the Transaction Date, Child 1, Child 2, Child 3, and Child 4 will each transfer to TC1, TC2, TC3 and TC4, as the case may be, such number of DC Common Shares having an aggregate FMV equal to one-quarter of the aggregate FMV of the Transaction Assets less one-quarter of the aggregate amount outstanding on the Parent Note and Parent Note 2 (in each case, the “ TC1 Transferred Shares”, “TC2 Transferred Shares”, “TC3 Transferred Shares” and “TC4 Transferred Shares”) in the manner described in Paragraphs 20 to 24. 20. ...

XXXXXXXXXX 2021-088647 XXXXXXXXXX, 2022 Object: Income Tax Ruling – Butterfly Transactions XXXXXXXXXX Dear XXXXXXXXXX, We are writing in response to your request for an advance income tax ruling (“Ruling Request”) dated XXXXXXXXXX behalf of the above-noted taxpayers (the “Taxpayers”). ...

The aggregate FMV, immediately before the transfer of the Newsub Common Shares by Canco to TSub described in Paragraph 80, of the common shares of TCo owned by Forco will be equal to or approximate the amount determined by the formula, on the assumption that Forco is the participant, Canco is the distributing corporation and TCo is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 73. ...