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Anderson/Freehold -- summary under Loss Utilizations/TRAs

Anderson then will transfer most of its assets to New Anderson, other than shallow gas assets (which are considered to be non-core assets) in consideration for assumption of liabilities and the issuance of New Anderson common shares – which will then be distributed to New Anderson for cancellation as a stated capital distribution. ... It is anticipated that by virtue of a ITA s. 66.7(7)(e) successor election, New Anderson will acquire resource pools of Anderson, whereas Anderson will retain non-capital losses and undepreciated capital cost of $222 million (with the $35 million purchase price subject ot adjustment if such tax attributes are less than $222 million). See full summary under Spin-Offs & Distributions – Taxable Spin-offs. ...

Hudbay/Augusta -- summary under Shares and Warrants

Hudbay/Augusta-- summary under Shares and Warrants Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Subsequent Acquisition Transactions- Amalgamations- Shares and Warrants Squeeze-out of remaining Augusta Resource shareholders on triangular amalgamation with Hudbay subsidiary in exchange for Amalco prefs (which are redeemed for warrants on Hudbay shares) and for Hudbay shares Overview Following the acquisition by Hudbay of most of the common shares of Augusta (the "Augusta Shares") in consideration for common shares of Hudbay ("Hudbay Shares") and for warrants to acquire common shares of Hudbay ("Hudbay Warrants"), there will be an amalgamation squeeze-out of the minority Augusta shareholders under which, on an amalgamation of Augusta with Newco, they will receive Hudbay Shares and redeemable preference shares of Amalco (having full stated capital). ...

Sierra/Cautivo Mining -- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds

For each whole right (a "Right") held, a holder will be entitled to subscribe for one common share of the Corporation (a "Share") at a price of $● per Share (the "Subscription Price") at any time from ●, 2017 to 5:00 p.m. (Toronto time) (the "Rights Expiry Time") on ●, 2017 (the "Rights Expiry Date"). ... Standby Agreement The “Standby Purchasers” (Arias Resource Capital Fund II L.P. and Arias Resource Capital Fund II (Mexico) L.P.) have agreed, severally and subject to stipulated conditions, that each of the Standby Purchasers will purchase its respective percentage of the shares that are not subscribed under Rights Offering. ...

Yamana/Extorre -- summary under Shares for Shares and Cash

Yamana/Extorre-- summary under Shares for Shares and Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Shares for Shares and Cash Yamana acquisition of Extorre for cash and shares with potential s. 85(1) rollover CBCA Plan of Arrangement under which Yamana (TSX and NYSE) acquires all of the outstanding common shares of Extorre (TSX and NYSE MKT). $3.50 of cash (estimated to represent 82% of the consideration) and 0.0467 of a Yamana common share is to be provided in exchange for each Extorre common share. ... In this regard, Extorre considers that its common shares do not currently derive more than 50% of their fair market value from Canadian resource properties etc. ...

S1-F3-C4 - Moving Expenses -- summary under

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). ...

TORC/Vero -- summary under Triangular Amalgamations

TORC/Vero-- summary under Triangular Amalgamations Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Amalgamations- Triangular Amalgamations Triangular amalgamation of TORC (a private company) with a wholly-owned subsidiary of Vero Overview The arrangement effectively represents an acquisition of TSX-listed Vero, seen as a high netback, light oil focused Cardium resource play, by TORC (an unlisted Alberta company), which is focused on the southern Alberta Bakken petroleum system. ...

Lowe’s/RONA -- summary under Canadian Buyco

Lowe’s/RONA-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco Lowe’s acquisition of RONA through exisiting Nova Scotia ULC Overview. ... Each DSU, RSU or PSU will be transferred by its holder to the Corporation in exchange for a cash payment from the Corporation of $24.00, except that such consideration in respect of each PSU granted in calendar year 2013 will be multiplied by the applicable level of achievement percentage determined by the Corporation’s Human Resources and Compensation Committee. ...

AuRico/Alamos/AuRico Metals -- summary under Shares for Shares and Nominal Cash

AuRico/Alamos/AuRico Metals-- summary under Shares for Shares and Nominal Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Shares for Shares and Nominal Cash Merger of AuRico and Alamos and s. 86 spin-off of AuRico Metals Overview Under an Ontario Plan of Arrangement, AuRico will acquire all the shares of Alamos ("Alamos Shares") in consideration for AuRico common shares ("AuRico Shares") and nominal cash (so that a s. 85 election is required for rollover treatment), and then amalgamate with Alamos. ... An acquisition of control of AuRico (which likely has significant Canadian resource pools) by Alamos under ITA s. 256(7)(c) will be avoided by having the AuRico Metals spin-off occur after the merger. ...

S1-F3-C4 - Moving Expenses -- summary under Eligible Relocation

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39 -- summary under Paragraph (c)

For these purposes, “Canadian resource property” is defined in section 370(b) of the QTA [by reference to] … a mineral resource in Canada …. ... On a literal reading of the relevant dispositions of the Q TA, these shares would constitute TQP … The result would be the same where the Canadian corporation was instead a foreign corporation. ... [Footnote 102 … document no. 07-010503 ….]. ...

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