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“The borrowing capacity of Parentco and its subsidiaries significantly exceeds the maximum amount... required to complete the Proposed Transactions ….” ...

ACo will partially repay the notes referred to above (other than Note 6, which will not be repaid for a specified number of months following the commencement of the proposed transactions) in order to pay estate income tax and make specific bequests – but not so as to result in a winding-up, discontinuance or reorganization of its business. ...

The payment to a Residual Beneficiary [in 2 above] will be included in the income of a Residual Beneficiary under sections 5 and 6 of the Act in the year of receipt and will be subject to the appropriate income tax withholding …. ...

“Moreover, any prior statements to the effect that a particular incentive plan does not give rise to a SDA because it is future-oriented at time of grant should not be construed as a categorical statement that all future-oriented plans fall outside the scope of the SDA rules.” “… [A]n incentive plan can be a SDA before the final value of the units has been determined at the occurrence of the triggering event. ...

Proposed transactions The estate will transfer its Class A and Class E shares of the Corporation to a newly-incorporated corporation (“Newco” – whose voting common shares are held by it) in consideration for Class A common shares and a Newco and two non-interest-bearing notes (“Note 1” and “Note 2”), electing under s. 85(1). ...

The consequences indicated by CRA included: S. 107(2)(a) deems the Trust to dispose of the Shares for proceeds of disposition (“POD”) equaling their “cost amount” of $100,000; S. 107(2)(b) deems the beneficiary to acquire the Shares at a cost equaling the total of their $100,000 “cost amount” to the Trust immediately before the distribution and any excess of the ACB to the beneficiary of the capital interest (nil) over its $100,000 “cost amount” – so that the beneficiary acquires the Shares at a cost of $100,000; S. 107(2)(c) deems the POD of the beneficiary’s capital interest to equal to the excess of the $100,000 cost to the beneficiary of the Shares over the $20,000 of eligible offsets, so that the beneficiary’s POD of the Trust capital interest is $80,000. ...

. … 2016-0667361E5 no longer represents the position of the CRA. ...

The two options are mutually exclusive and exhaustive – either the French Treaty applies to the full amount of the dividend, or the US Treaty applies pro-rata to the US partners. ...

., a “right under a contract … to control the voting rights attached to the share.” ...

Parentco1, 2 and 3 will transfer all of its shares of DC to Holdco on a s. 85(1) rollover basis in consideration for corresponding shares of Holdco – and similarly for Parentco2 and 3. ...