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(formerly, Connor, Clark & Lunn Capital Markets Inc.), as manager (the ' ' Manager'') and RBC Investor Services Trust as trustee. ...

The Trust will issue different series of credit card receivables-backed notes (the "Notes"), which will have recourse only to an undivided co-ownership interest in a revolving pool of credit card receivables generated under by PC Bank and certain related assets (a “Series Co-Ownership Interest”) – and the Note proceeds will be used to acquire that co-ownership interest form PC Bank. ... " Receivables The " Receivables " included in the Account Assets are the aggregate amounts (being all Finance Charge Receivables and Principal Receivables) charged to related Accounts. ...

First Quantum/Inmet-- summary under Unsolicited Bids (corporate) Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Unsolicited Bids (corporate) First Quantum Unsolicited Share and Cash Bid for Inmet Offer FQM (Akuba) Inc. (the "Offeror"), which is a CBCA wholly-owned subsidiary of First Quantum (which is a TSX-listed and LSE-admitted BCBCA company), is offering to each shareholder of Inmet (which is a TSX-listed CBCA company) the following consideration for each share of Inmet (conditional inter alia on at least 66 2/3% of the Inmet shares on a fully-diluted basis being deposited): • $72 in cash; • 3.2967 common shares of First Quantum; or • $36 in cash and 1.6484 common shares of First Quantum. ... Compulsory Acquisition/Subsequent Acquisition Transaction If 90% acceptance, First Quantum will acquire the balance of the Inmet shares under a Compulsory Acquisition Transaction "on the same terms as…under the Offer – and otherwise under a Subsequent Acquisition Transaction. ...

Trust Note interest The interest rate on the Trust Notes — Series 2017-A will initially be 5.30% per annum, payable in arrears. ... Guarantee by TCPL TCPL will guarantee, on a subordinated basis, the Trust Notes — Series 2017-A and all the Trust's obligations to the holders of the Trust Notes — Series 2017-A pursuant to the Share Exchange Agreement and the Assignment and Set-Off Agreement. ... No OID/deferral prospect remote Under applicable Treasury regulations, the possibility that interest on the Trust Notes — Series 2017-A might be deferred could result in the Trust Notes — Series 2017-A being treated as issued with original issue discount (''OID''), notwithstanding that the Trust Notes — Series 2017-A are issued at par, unless the likelihood of such deferral is remote. ...

Sprott/Central Goldtrust-- summary under Bullion Fund Mergers Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- Section 132.2 Mergers- Bullion Fund Mergers Sprott Physical Gold Trust offer of units for Central Goldtrust units providing taxable exchange and s. 132.2 alternatives Overview The Offeror is making the "Offer" to purchase all of the issued and outstanding GTU Units (other than those held directly or indirectly by the Offeror). ... GTU Trustees' response Their 19 June 2015 letter to unitholders (recommending rejection) stated: The Sprott Offer does not provide any meaningful premium, but asks Unitholders to exchange their Units for units of Sprott PHYS, which involve higher costs, increased tax risks, and reduced governance rights. … Sprott PHYS' physical redemption feature is substantially the same as the one that Polar Securities proposed that GoldTrust adopt – a proposal that was overwhelmingly rejected by over 80% of votes cast (excluding Polar) at GoldTrust's Annual and Special Meeting of Unitholders held just last month. … Sprott PHYS' redemption feature would expose certain non-redeeming U.S. ... An exchange of GTU Units for PHYS Units pursuant to the Exchange Offer Election or the Merger Transaction should be treated as a single transaction for U.S. federal income tax purposes that is intended to qualify as a ''reorganization'' under Section 368(a) of the Code (a ''Reorganization ' '). ...

Goldcorp/Osisko-- summary under Unsolicited Bids (corporate) Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Unsolicited Bids (corporate) Cash and share bid of Goldcorp for Osisko Offer Holders of common shares of Osisko are offered C$2.26 in cash and 0.146 of a Goldcorp common share for each share. ... In addition, the US federal income tax analysis with respect to each Osisko Shareholder will depend in part upon whether Osisko is treated as a PFIC with respect to such Osisko Shareholder. … Osisko has indicated in a public filing that it believes that it was a PFIC in prior years. ...

Brookfield Infrastructure/Enercare-- summary under Exchangeable Units Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- LP Acquisitions of Corporations- Exchangeable Units acquisition of Enercare Inc. through combination of cash and Exchangeable LP units Overview On October 16, 2018, Brookfield Infrastructure acquired all of the 107M common shares of the Company (being all its shares) under a CBCA Plan of Arrangement. ... Exchangeable unit consideration A Resident Holder who is an Electing Canadian Shareholder may choose to defer all or a portion of any capital gain that would otherwise be realized on the exchange of Common Shares for Exchangeable LP Units or (in the case of proration or a Partial Unit Election) for Exchangeable LP Units and cash from Exchange LP pursuant to the Arrangement by filing with the CRA (and, where applicable, with a provincial tax authority) a joint election (the ''Joint Tax Election '') under s. 97(2). ...

Sirius XM-- summary under Exchangeable Share Acquisitions Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Exchangeable Share Acquisitions exchangeable shares offered by Canadian-controlled purchaser (minority-owned by Sirius XM (Del.) sub) Overview A Delaware subsidiary (the “Guarantor”) of SIRI holds approximately a 37% equity interest in the “Company (some of it in the form of non-voting shares to address CRTC non-resident control issues) and two Canadian corporations (Slaight and Obelysk), together have approximately a 22.4% equity interest in the Company. ... Company ownership Principal Shareholder Type of Ownership Number of class A Shares assuming conversion of Class B and Class C Shares Percentage of Class A Shares Outstanding assuming conversion of Class B and Class C Shares Voting Interest represented by # of Voting Shares Percentage of Votes Obelysk Direct 12,982,135 10.09% 23,154,901 17.08% Guarantor Direct 47,324,180 36.77% 33,685,653 24.85% CBC Direct 13,056,787 10.15% 13,056,787 9.63% Slaight Direct 15,856,787 12.32% 26,170,361 19.31% Obelysk holds its interest in the form of 15,259,149 Class B Shares and 7,887,307 Class A Shares. ...

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. ...

Loblaw/Shoppers-- summary under Shares for Shares and Nominal Cash, or Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Shares for Shares and Nominal Cash, or Cash Loblaw acquisition of Shoppers Drug Mart for cash, or shares plus $0.01 per share cash Overview All the shares of TSX-listed Shoppers Drug Mart are to be acquired under a CBCA plan of arrangement by Loblaw, which is a CBCA company listed on the TSX, in consideration (subject to dissenter share adjustments) for 119.9M Loblaw shares and $6.67B cash (with the overall consideration of $12.4B representing a 29.4% premium). ... Plan of Arrangement Under the Plan of Arrangement: • the Shoppers Drug Mart shareholder rights plan will be cancelled • Shoppers Drug Mart shares of dissenters will be transferred to Loblaw, with an entitlement to be paid their fair value • vested RSUs will be surrendered for cash payments; and other RSUs or DSUs will be continued so as to apply to Loblaw shares, subject to adjustments for the exchange ratio • all outstanding options to acquire Shoppers Drug Mart shares will be exchanged for replacement options on Loblaw shares, with adjustments for the exchange ratio in accordance with s. 7(1.4)(c) • each outstanding Shoppers Drug Mart share will be transferred to Loblaw for the Cash Consideration or Share Consideration, subject to pro-ration Canadian tax consequences In the absence of an s. 85 election, the exchange will occur on a non-rollover basis (with ACB averaging not occurring re Loblaw shares acquired before 1972). The deadline for providing an. s. 85(1) or (2) election form to Loblaw is 90 days after the Effective Date of the plan of arrangement – with Loblaw to return within 90 days. ...