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The terms of the Holdco I Note will provide that a portion of the interest payable on the note (approximately XXXXXXXXXX %) will be paid in the taxation year the expense is incurred and the unpaid portion will be paid prior to the end of the second taxation year following the taxation year in which the expense was incurred. 19. ...

XXXXXXXXXX will sell, at fair market value, to Subco XXXXXXXXXX % of its cash and near-cash property and investment property. ...

The Exercise Price will be approximately XXXXXXXXXX % of the market price (on the XXXXXXXXXX Stock Exchange) of the CCo Stock (XXXXXXXXXX) on the date on which the offering of the Units is priced. ...

On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $ XXXXXXXXXX. 20. ...

Position TAKEN: 1) No 2) No 3) Yes 4) No Reasons FOR POSITION TAKEN: 1) Consistent with the position in IT-385R2 and in previous rulings (973094, 972779 & 970604) 2) The variation is not significant enough to consider that there has been a disposition (972779). 3) The Distribution pursuant to subsection 107(2) is consistent with Finance's comments contained in the Technical Notes regarding the 21-year rule. 4) This issue was referred to the GAAR Committee and it was recommended that GAAR not apply to the proposed transactions. ...

(b) Canco1 and the Lessee entered into a purchase and sale agreement ("Purchase and Sale Agreement ") which provided, inter alia, that Canco1 would sell the XXXXXXXXXX to the Lessee for $XXXXXXXXXX on XXXXXXXXXX or such later agreed date. 4. ...

The rulings are virtually identical except that in this ruling the dividend rate on the preferred shares exceeds the interest rate on the loan by XXXXXXXXXX % whereas in the prior ruling the dividend rate on the preferred shares is equal to the interest rate on the loan. ...

The original shareholdings of DC on incorporation were as follows: Shareholder Number of shares % Class of shares Stated capital W XXXXXXXXXX "A" $XXXXXXXXXX S XXXXXXXXXX "A" $XXXXXXXXXX 8. ...

M Class A Preference XXXXXXX XXXXXXX XXXXXXX Bco Common XXXXXXX XXXXXXX XXXXXXX Cco Common XXXXXXX XXXXXXX XXXXXXX The Class A Preference shares of Aco are non-voting, redeemable, retractable for an amount of $XXXXXXXXXX and entitled to non-cumulative dividends at the rate of XXXXXXXXXX % per annum of the redemption amount. ...

The General Partner will receive an undivided XXXXXXXXXX% interest in the preferred shares distributed, and the Limited Partners will receive an undivided XXXXXXXXXX % interest in the preferred shares distributed. 40. ...