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Kingsett & OPB/Primaris-- summary under Unsolicited Bids Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- Unsolicited Bids KingSett/OPB joint bid for Primaris (superceded by Primaris merger with H&R) Offeror The Offeror is an Ontario LP whose LP units are owned equally by an affiliate of KingSett Capital, and OPB Trust, an associate of OPB. ...

(‘‘MPI’’) which is part of the Minto Group of companies (collectively, ‘‘Minto ’ ’), Since its inception in 1955, Minto has built more than 85,000 new homes, and it currently manages over 13,000 residential suites and a commercial portfolio of more than 2.5 million square feet of office and retail space; and it has more than 1,100 full-time employees in Canada and the U.S.. ... Capitalization Immediately following Closing, the Debt to Gross Book Value Ratio of the REIT is expected to be as follows: Assumed Debt.................................................. $ 239,145 Class C Units.................................................... 233,282 Unsecured promissory note......................................... 25,797 Principal amounts outstanding under the Credit Facility..................... 28,458 Indebtedness................................................... $ 526,682 Gross Book Value............................................... $1,128,955 Debt to Gross Book Value Ratio (inclusive of mark-to-market)................ 46.7% Transaction steps Prior to Closing MPI formed a number of wholly-owned entities, including Minto Apartment GP Inc. ... Unit redemption rights Upon receipt of the Redemption Notice by the REIT, all rights to and under the Units tendered for redemption shall be surrendered and the holder thereof will be entitled to receive a price per Unit (the ‘‘Redemption Price’’) equal to the lesser of: (a) 90% of the ‘‘Market Price’’ of a Unit calculated as of the date on which the Units were surrendered for redemption (the ‘‘ Redemption Date’ ’); and (b) 100% of the ‘‘Closing Market Price’’ on the Redemption Date. ...

See full summary under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Reverse Takeovers. ...

Mitel/Polycom-- summary under Inversions Summary Under Tax Topics- Public Transactions- Other- Continuances/Migrations- Inversions acquisition of Polycom by Mitel in Delaware merger for cash and Mitel shares Overview The acquisition of Polycom, a NASDAQ-listed U.S. corporation by Mitel (a TSX and NASDAQ-listed Canadian corporation) in a Delaware merger (in which an indirect Delaware sub of Mitel (“Merger Sub”) is merged into Polycom, with Polycom as the survivor) is structured so that it will be treated for accounting purposes as a purchase by Mitel and as not causing Mitel to be deemed to be a U.S. corporation under Code s. 7874 – even though the market cap of Polycom is almost 50% greater than that of Mitel. ... See detailed summary under Mergers & Acquisitions – Cross-Border Acquisitions – Outbound – Delaware Mergers. ...

Rio Alto/Sulliden-- summary under Shares for Shares and Nominal Cash Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- S. 86 spin-offs- Shares for Shares and Nominal Cash S. 86 spin-off of Quebec property of Sulliden, and its acquistion on share-for share exchange by Rio Alto and amalgamation with Rio Alto subsidiary as a s. 368(a) reorg Overview Following the spin-off of SpinCo on a s. 86 reorg of Sulliden on the basis of 0.10 of a SpinCo Share for each (common) Sulliden Share, all of the outstanding Sulliden Shares will be exchanged for (common) Rio Alto Shares on the basis of 0.525 of one Rio Alto share for each Sulliden Share. ... See full summary under Mergers & Acquisitions – Mergers – Share-for-share. ...

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

" See full summary under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – Taxable Trust Mergers. ...

Chalice/Coventry-- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Ss. 84(4.1)(a) and (b) distributions of proceeds Chalice Gold acquisition of Coventry Resources assets for shares, followed by share distribution Overview Under a BC Plan of Arrangement, Coventry is to transfer most of its subsidiaries (the "Targets") to Western Rift (a subsidiary of Chalice) in consideration for Chalice shares, which Coventry will then transfer to its shareholders as a stated capital distribution. ... See detailed summary under Cross-Border Acquisitions – Inbound – Asset sale/share distribution. ...

Gastar-- summary under Outbound continuances Summary Under Tax Topics- Public Transactions- Other- Continuances/Migrations- Outbound continuances Continuance of Gastar Exploration from Alberta to Delaware Overview Pursuant to a Plan of Arrangement under s. 193 of the ABCA, the jurisdiction of incorporation of Gastar will be changed from Alberta to Delaware by way of a domestication under s. 388 of the Delaware General Corporation Law ("DGCL") – so that its existence as a corporation will be deemed to have commenced on December 22, 2005, the date of original incorporation under the ABCA. ... Holders – s. 367 If the continuance qualifies as a Code s. 368(a) reorganization, U.S. holders of Gastar shares generally will not recognize any gain or loss for Code purposes upon the exchange of their Gastar shares for shares of New Gastar pursuant to the continuance unless the Code s. 367 rules or PFIC rules apply. ... Holders – PFIC Gastar believes that it is not and never has been a PFIC. ...

Holders – s. 367 U.S. holders of Revett Minerals shares generally will not recognize any gain or loss for Code purposes upon the exchange of their Revett Minerals shares for shares of New Revett Minerals pursuant to the continuance unless the Code s. 367 rules or PFIC rules apply. ... Holders – PFIC Revett Minerals believes that it is not and never has been a PFIC. ...