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Whether 7(1.5) applies sequentially to (i) the exchange of the DC Common Shares and (ii) to the exchange of the DC Butterfly Series 1 and 2 Shares received in (i); 2. ... Yes. 2. No. 3. No. Reasons: 1. Previous positions. 2. Application of section 49.1. 3. ... Transfer of DC Butterfly Series 2 Shares to Spinco2 29. Each Participant will transfer all such Participant's DC Butterfly Series 2 Shares to Spinco2 in exchange for Spinco2 Common Shares. ...

Remboursement du Billet 2 46. Amalco procédera au remboursement graduel du Billet 2 s’assurant toutefois que les montants payés trimestriellement à la Succession au cours de l’année suivant la date de la Fusion n’excèdent pas XXXXXXXXXX % du principal du Billet 2: a) XXXXXXXXXX% du principal du Billet 2; b) XXXXXXXXXX % du principal du Billet 2; c) XXXXXXXXXX % du principal du Billet 2; d) XXXXXXXXXX% du principal du Billet 2. 47. Amalco ne cessera pas d’exploiter son entreprise de placement avant le remboursement de la totalité du principal du Billet 2. 48. Au moment opportun, la Succession pourra distribuer les fonds provenant du remboursement du principal du Billet 1 et du Billet 2 aux Héritiers. ...

On the incorporation of Newco 2, Foreign Pubco Sub 2 will subscribe for one or more membership interests of Newco 2 for nominal consideration. 66. Foreign Pubco Sub 2 will transfer XXXXXXXXXX to Newco 2 in exchange for membership interests of Newco 2 and the assumption of certain liabilities. 67. Foreign Pubco Sub 2 will distribute the membership interests of Newco 2 to Foreign Spinco. ...

2. Will subsection 39(2) apply where a debt is exchanged for a different debt or modifications are made to a debt? Position: 1. and 2. Yes. Reasons: 1. The transactions respect the law. 2. ... The FMV of the Vanilla Loan 2 is XXXXXXXXXX. The Vanilla Loan 2 is a capital property to LP. ...

As at XXXXXXXXXX, DC’s primary assets consisted of: a) the Rental Properties; b) XXXXXXXXXX Class A common shares of the capital stock of Holdco 2, which represent XXXXXXXXXX% of the issued and outstanding shares of the capital stock of Holdco 2; and c) amounts receivable from Holdco 2. ... Holdco 2 14. Holdco 2 is a CPCC and a TCC. Holdco 2 is governed by the XXXXXXXXXX and is a resident of Canada. ... For greater certainty, DC will transfer to TC Sub its pro rata share of the shares of the capital stock of Holdco 2, and any amounts receivable from Holdco 2. ...

A Co is a taxable Canadian corporation and a CCPC incorporated under the BCA. 2. ... Facts Relating to Partnership 2 65. Partnership 2 is a general partnership that was formed under the laws of XXXXXXXXXX, by a partnership agreement dated XXXXXXXXXX. 66. ... The fiscal year-end of Partnership 2 is XXXXXXXXXX. 69. Partnership 2 was formed to XXXXXXXXXX land under development and revenue-producing real property located primarily in XXXXXXXXXX. ...

Sibling 1 and Sibling 2 are brothers and are adult children of Late Father. 2. Both Sibling 1 and Sibling 2 are Canadian residents for income tax purposes. 3. ... Sibling 2 has no children. 5. Late Father passed away on XXXXXXXXXX. 6. ...

Parentco is currently governed under the XXXXXXXXXX and has a XXXXXXXXXX taxation year-end. 2. ... The issued and outstanding shares in the capital of Holdco 2 are held as follows: Shareholder Number and Class of Shares ACB PUC Aggregate redemption amount Sibling 2 XXXXX Class B preferred shares XXXXX XXXXX XXXXX XXXXX Class C preferred shares XXXXX XXXXX XXXXX XXXXX Class D preferred shares XXXXX XXXXX XXXXX Trust 2 XXXXX Class A common shares XXXXX XXXXX XXXXX 13. ... The trustees and beneficiaries of Trust 1, Trust 2 and Trust 3 are residents of Canada for the purposes of the Act. ...

Position: 1) No 2) Question of Fact 3) Not necessarily 4) Not Necessarily 5) No Reasons: 1) Trust is not an Indian under s. 87 of Indian Act 2) Depends on functions performed by Band. 3) Trust may be entitled to deduction if Band can enforce payment pursuant to 104(6) and 104(24). ... You are asking for our consideration of the following five questions: We will address each of your questions below: Question 1 Is the Trust revenue taxable if it is derived from 1) a savings account located at a bank branch situated on the reserve, or 2) investments in certain authorized debt or equity instruments? ... Question 2 Does the Band qualify to be exempt from tax pursuant to paragraph 149(1)(c) of the Income Tax Act (the "Act")? ...

2. Are the monthly fees paid by the Customers to Corporation C for the performance of services exempt from withholding tax? ... Treaty exempts royalty payments in respect of works for private home use. 2. ... Contract 2- Customer B as Merchant of Record 15. Corporation C, through its CyberABC platform, will operate Customer B's Online Store only as a technology and service provider. ...