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Unit pricing The price per Trust Unit will be: Class A, A1, B and B1 Trust Units (Denominated in C$) Class U and U1 Trust Units (Denominated in US$) On or before August 31, 2016 $ 9.00 $ 9.00 On or before December 31, 2016 $ 9.50 $ 9.50 On or before June 30, 2017 $ 9.75 $ 9.75 After June 30, 2017 $ 10.00 $ 10.00 Trust An open-ended Alberta unit trust whose units will not be listed. ... The Trust anticipates being fully invested within nine months of Final Closing (being the earlier of (i) December 31, 2017; or (ii) the date on which the $100,000,000 has been raised by the Offering – subject to extension at the Manager’s discretion. ... Canadian tax consequences MFT status/SIFT rules It is assumed that the Trust will qualify as a "mutual fund trust" – and that the Trust Units will not, at all relevant times, be listed or traded on a stock exchange or other public market and, accordingly, that the Trust will not be liable for the SIFT Tax. ...

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. ... See full summary under Spin-Offs & Distributions – Taxable Spin-offs. ...

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 ' '). ...

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. ...

Fission/Alpha-- 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-offs of exploration companies by Alpha Minerals and Fission Uranium, and acquisition of Alpha Minerals by Fission Uranium Overview Alpha and Fission (both TSXV-listed, and ABCA and CBCA corporations, respectively) will be transferring various (mostly uranium) exploration assets to Alpha Spinco and Fission Spinco and spinning-them off (per the s. 86 rules) under ABCA and CBCA Plans of Arrangement (the Alpha Arrangement and Fission Arrangement), with each Alpha share then being transferred to Fission under the Alpha Arrangement for 5.725 Fission common shares and nominal cash (so that no rollover treatment obtains unless a s. 85 election is filed). ... For a more detailed summary, see under Mergers & Acquisitions- Mergers – Shares for Shares and Nominal Cash. ...

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. ...

., reorganization as Deans Knight Income Corporation, resulting in its shelter being utilized in a new bond- investing business financed on an IPO For the subsequent CRA attack, see under Spin-Offs & Distributions – Liquidations. ...

Rupert/Hudson's Bay-- summary under Inbound Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound privatization in favour of Newco LLC for continuing NR shareholders with resulting deemed dividend Overview A grouping of non-resident shareholders holding over 60% of the HBC common shares transferred their shares to a newly-formed LLC under a Plan of Arrangement and pursuant to “rollover agreements” (presumably so termed because their HBC shares were not viewed as taxable Canadian property). ... L & RB Entities Collectively, Richard A. Baker, Lisa Baker, Lisa and Richard Baker Enterprises, LLC, Red Trust, Yellow Trust and Blue Trust; L&T B Group L&T B (Cayman) Inc. Table of significant Company insiders’ percentage of common shares (preferred shares for Fabric) Name Common Shares (%) Richard Baker 6.37 Robert Baker 2.16 William Mack 0.49 Lee Neibart 1.79 The Catalyst Capital Group Inc. 17.44 L&T B (Cayman) Inc. 15.58 Hanover Investments (Luxembourg) S.A. 17.45 Fabric Luxembourg Holdings S.à r.l. 100.00 Plan of Arrangement a portion of the Common Shares held by the L & RB Entities will be transferred and assigned to New Holdco pursuant to a Rollover Agreement… simultaneously with (i) above, each Common Share or Preferred Share held by the Continuing Shareholders (other than those being transferred pursuant to (i) above) will be transferred and assigned to New Holdco pursuant to Rollover Agreements… each Common Share held by Dissenting Shareholders will be transferred to the Company in consideration for a claim against the Company. each Common Share other than (a) Common Shares held by a Dissenting Shareholder who has validly exercised such holder’s Dissent Right, or (b) Common Shares held by New Holdco or the Continuing Shareholders, will be purchased by the Company in exchange for the “Consideration” of $11.00 in cash per Common Share. each Preferred Share will be converted into a number of Common Shares calculated in accordance with the terms of the Preferred Shares. each DSU and RSU will be transferred to the Company in exchange for a cash payment from the Company equal to the Consideration. each Option will be transferred by the holder of such Option to the Company in exchange for a cash payment from the Company equal to the amount by which the Consideration exceeds the exercise price per Common Share of such Option.The cost to fund the Consideration is estimated to be approximately $1.11 billion, which will be funded through existing cash resources of the Company and the Debt Financing. ...

Agnico/Yamana/Osisko-- 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 Osisko s. 86 spin-off of New Osisko and exchange of Osisko shares for cash and shares of Agnico and Yamana Overview Under a CBCA Plan of Arrangement, each Osisko common share will be exchanged under s. 86 for one new (Class A) common share of Osisko and a common share of a newly-formed subsidiary (New Osisko). ... See full summary under Mergers & Acquisitions- Mergers- Shares for Shares & Cash. ...

Anderson/Freehold-- summary under Taxable spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Taxable spin-offs Distribution of Anderson Energy core assets to New Anderson and sale of Anderson Energy to Freehold Overview The Anderson shareholders will transfer all their common shares of Anderson under an Alberta Plan of Arrangement to a new Alberta company (New Anderson) in exchange for an equal number of New Anderson common shares. 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. ... Anderson will be deemed to have filed an election under ITA – s. 89(1) – (c) to not be a public corporation. ...