Search - 临汾市2天旅游行程

Following completion of the Arrangement but prior to the completion of the Rights Offering, existing Shareholders will own 2% of the outstanding Common Shares, and the former Debentureholders and Brookfield will hold 6% and 92%.. ...

Pacific Rubiales will jointly elect under s. 85(1) or (2) with eligible holders (Canadian residents, and non-residents whose shares are taxable Canadian property and not treaty-protected property) provided that it is provided with two signed and complete copies of the election form by 45 days following the effective date of the plan of arrangement. ...

Canadian tax consequences Taxable exchange if no election A Resident Holder whose Common Shares are exchanged for the Consideration pursuant to the Reorganization and who does not make a valid tax election referred to below (a “Tax Election”) with respect to the exchange in 2 above, will realize a capital gain (or capital loss) equal to the amount by which the proceeds of disposition, net of any reasonable costs of disposition, exceed (or are less than) the adjusted cost base of the Resident Holder’s Common Shares immediately before the exchange. ...

.), FrontFour (FrontFourCapital Group LLC), the Sandpiper Partnerships (Sandpiper Opportunity Fund 7 LP, Sandpiper Real Estate Fund 2 LP and Sandpiper Real Estate Fund 4 LP), Artis (Artis Real Estate Investment Trust) and KREI (Koch Real Estate Investments LLC). ...

Transactions Steps 2 to 13 below will occur pursuant to a CBCA Plan of Arrangement: KPI will contribute its Class A units of SLP to New LP in consideration for a note (the New LP Note) and units of New LP. ...

Transfer to New FSV The transfer of FirstService MV Special Shares and FirstService SV Special Shares to New FSV will occur on a rollover basis under s. 85.1 unless the transferor shareholder chooses to elect capital gains or capital loss treatment on the transfer or jointly elects under s. 85(1) or (2). ...

Plan of Arrangement steps Simultaneously with 2 and 3 below, each holder of a Bacanora Canada Share outstanding at the Effective Time, will transfer its Bacanora Canada Shares to AcquireCo in exchange for Bacanora UK Shares on the basis of one Bacanora Canada Share for one Bacanora UK Share; AcquireCo will issue that number of common shares of AcquireCo to Bacanora UK at a deemed value of $1.00 per common share of AcquireCo equal in value to the total number of Bacanora UK Shares issued by Bacanora UK to each Bacanora Canada Shareholder; In consideration of AcquireCo issuing its common shares to Bacanora UK, Bacanora UK will issue Bacanora UK Shares to each Bacanora Canada Shareholder in exchange for such Bacanora Canada Shareholder tendering its Bacanora Canada Shares to AcquireCo, on a one for one basis; The stated capital of the Bacanora Canada Shares shall be reduced, in the aggregate to $1.00; Bacanora Canada and AcquireCo shall be amalgamated as one corporation. ...

Plan of Arrangement The Purchaser shall make a non-interest-bearing demand loan to the extent required by the Company to make the payments in 2 below. ...

Assuming the Arrangement is treated as a tax-deferred recapitalization then, subject to PFIC considerations, the U.S. holders who receive Resulting Issuer Common Shares and Initial Put Rights will recognize gain (but not loss) to the extent of the lesser of (1) the excess of the fair market value of the Resulting Issuer Common Shares and the fair market value of the Initial Put Rights received on the date of receipt over the adjusted tax basis of the Mercator Shares surrendered, and (2) the fair market value of the Initial Put Rights on the date of receipt. ...

This is similar to the Fund No. 1 (summarized below) and No. 2 offerings. ...