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As such, F’s deemed proceeds of disposition were $XXXXXXXXXX, pursuant to subparagraph 70(6)(b)(ii), resulting in $ XXXXXXXXXX capital gain for F’s XXXXXXXXXX taxation year. ...

XXXXXXXXXX 2020-086244 XXXXXXXXXX Dear XXXXXXXXXX: Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling – Subsection 84(2) and Charitable donation XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling (“Ruling”) on behalf of the above-named taxpayers. ...

XXXXXXXXXX 2021-088901 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Redemption of Mutual Fund Trust Units Held by Registered Plans XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...

The number and classes of such shares and their FMV immediately before the Deceased’s death were as follows: Type of shares Class # of shares FMV Common Class 1 XXXXXXXXXX XXXXXXXXXX Common Class 2 XXXXXXXXXX XXXXXXXXXX Special Class A XXXXXXXXXX XXXXXXXXXX Special Class B XXXXXXXXXX XXXXXXXXXX Special Class C XXXXXXXXXX XXXXXXXXXX 6. ...

Step 9 – there is no non-resident vendor and the purchaser is Taxpayer 6 for the acquisition of all issued and outstanding common shares of Taxpayer 11. 21. ...

The tax attributes attached to the shares of Opco immediately before the Deceased’s death were as follows: Shareholder Number & Class of FMV ACB PUC Shares of Opco Deceased XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class E Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class F Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class Z Special Shares XXXXX XXXXXX XXXXX Child 1 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 2 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 5 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 6 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 7 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX 7. ...

XXXXXXXXXX 9.The XXXXXXXXXX units of XXXXXXXXXX are owned by over XXXXXXXXXX individuals and corporations that deal at arm's length with XXXXXXXXXX. 10.The TSO, taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of XXXXXXXXXX are as follows: Corporation TSO\TC RCT # XXXXXXXXXX 11.XXXXXXXXXX is a taxable Canadian corporation and a public corporation whose shares are listed for trading on the XXXXXXXXXX exchange. ...

The aggregate FMV, immediately before the DC Transfer, of the Foreign Spinco XXXXXXXXXX owned by Forco 3 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 3 is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ...

Holders may put the Convertible Senior Notes to TARGET in exchange for cash on XXXXXXXXXX at a purchase price equal to XXXXXXXXXX % of the principal amount plus accrued and unpaid interest. ... HOLDCO 1 and SHAREHOLDER 2-SUBCO 1 hold respectively XXXXXXXXXX % and XXXXXXXXXX% of the issued and outstanding shares of the capital stock of FINANCECO. ...

The DC Common Shares trade on the Stock Exchange under the symbol "XXXXXXXXXX ". ... The fair market value, immediately before the transfer described in Paragraph 28, of each Participant's Spinco Common Shares will equal or approximate the amount determined by the formula: (A x B/C) + D in respect of such Participant, as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...