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No more than 25% of the outstanding Shares of each class may be redeemed by March 31, 2015 – and thereafter, no more than 10% annually. ...

Tyco/ADT-- summary under Code s. 355 spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Code s. 355 spin-offs Tyco spins off ADT- and Tyco Flow Control in reverse Morris Trust acquisition structure Current structure Tyco is a Swiss NYSE-listed corporation limited by shares (Aktiengesellschaft). ...

Petrominerales-- summary under S. 84(2) spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- S. 84(2) spin-offs Spin-off by Petrominerales of Brazilian assets through PUC distribution, and its cash acquisition by Pacific Rubiales Overview Pacific Rubiales, which is a B.C. corporation listed on the TSX and an oil and gas producer operating through wholly-owned subsidiaries in Columbia and elsewhere, is to acquire Petrominerales after Petrominerales has first distributed (as a stated capital distribution occurring under an Alberta Plan of Arrangement) its Brazilian exploration assets (with a book value of $32M) to the Petrominerales shareholders in the form of ResourceCo which, in turn, will hold those Brazilian assets through a Brazilian subsidiary (Alvorada), and will also be capitalized with $100M of cash. ...

Yoho/Storm-- 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 Yoho Resources spin-off of Strom shares using change in shareholders' requisition rights to qualify under s. 86 Overview A subsidiary partnership of Yoho (Yoho Partnership) sold natural gas acreage to Storm on January 31, 2014 in consideration for $30M cash and 13.6M common shares of Storm (valued at that time at $4.25 per share). ...

New Gold/Rainy River-- summary under Shares for Shares or Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Friendly Corporate Offers- Shares for Shares or Cash New Gold friendly offer for Rainy River Offer Each holder of common shares of (TSX-listed) Rainy River may elect to receive $3.83 per share in cash or 0.5 of an New Gold share for each Rainy River share and associated shareholder rights plan rights ("SRP Rights") deposited under the offer (which is conditional, inter alia, on 66 2/3% of the issued and outstanding Rainy River shares (calculated on a fully-diluted basis) being tendered), except that the total amount of cash available under the offer and is limited to $198M 9pro rated for the proportion of the Rainy River shares which are taken up), and the total number of New Gold shares issuable under the offer is limited to 25.8M shares (also pro-rated). ...

SASC/HDG-- summary under Share-for-Share Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Share-for-Share Acquisition by South American Silver of High Desert Gold in exchange for SASC shares which do not participate in any expropriation award Overview TSXV-listed HDG is being acquired under a joint BC plan of arrangement by TSX-listed SASC on the basis of 0.275 of a SASC share for each HDG share. ...

Capital BLF/BLF REIT-- summary under CPC/Microcap Conversions Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- CPC/Microcap Conversions Conversion of Capital BLF Inc. into BLF REIT Overview Under a CBCA Plan of Arrangement, the shareholders of the Corporation will transfer their shares to a subsidiary Quebec LP of the REIT (BLF LP) on a taxable basis under a three-corner exchange arrangement, for REIT Units on a 40-for-1 basis (the "Exchange Ratio")- or, if they wish to and elect to transfer on a s. 97(2) rollover basis and their status is consistent with BLF LP qualifying as an excluded subsidiary entity (e.g., they are not individuals), they will transfer their shares to BLF LP for exchangeable LP units of BLF LP (the "Exchangeable LP Units") in accordance with the Exchange Ratio together with an equal number of special voting units of the REIT. ...

DeeThree/Boulder/Granite Oil-- summary under Butterfly spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Butterfly spin-offs Butterfly spin-off by DeeThree Exploration of Boulder Energy Overview Under an Alberta Plan of Arrangement, DeeThree will transfer its Brazeau Belly River assets (the "Spin-Off Assets") on a rollover basis to Boulder in connection with a butterfly spin-off of Boulder to its shareholders. ...

Intrepid-- summary under Capital distributions Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Foreign distributions- Capital distributions Intrepid Mines capital distribution Overview Intrepid Mines, an Australian company, is proposing to distribute approximately 87% of its assets in cash as a capital distribution. ...

ISG-- summary under S. 84(3) redemption spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- S. 84(3) redemption spin-offs Conversion of ISG to a REIT (Firm Capital Property Trust): s. 84(3) redemption of shares for cash or REIT units Overview With a view to all the common shareholders of ISG becoming the unitholders of the Trust, which is expected to be a REIT, ISG will sell its sole real estate asset and then, under a CBCA Plan of Arrangement, each ISG common shareholder will have the option of redeeming its shares for cash or for units of the Trust, so that following the Plan of Arrangement, ISG will be wholly-owned by the Trust. ...