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For the purpose of determining the Agreed Amount of the depreciable property of a prescribed class, the reference to "... the undepreciated capital cost to the taxpayer of all property of that class immediately before the disposition... ...

Investors may choose to finance up to approximately XXXXXXXXXX % of their investment in Units by way of a Unit Loan from the Unit Lender. ...

In either case, on a diluted basis, the public or such party or parties will own less than 50 % of the issued and outstanding voting shares in the capital of PublicCo. ...

To the best of the knowledge of the directors and senior officers of Canco, as of the date hereof, no person or group of related persons beneficially owns, directly or indirectly, more than ten percent of the issued and outstanding common shares of Canco, except XXXXXXXXXX who holds approximately XXXXXXXXXX % of Canco's issued common shares either directly or through XXXXXXXXXX ("Xco") a private company which is wholly-owned by him. 8. ...

XXXXXXXXXX owns XXXXXXXXXX units of XXXXXXXXXX, representing approximately XXXXXXXXXX % of the XXXXXXXXXX issued and outstanding units of XXXXXXXXXX, In XXXXXXXXXX announced its intention to commence normal course purchases of units of XXXXXXXXXX through the facilities of XXXXXXXXXX. ...

The share capital of each new corporation will consist of: (a) a class of common shares; and (b) a class of special shares designated as Class A special shares with the following share attributes: (i) voting; (ii) redeemable and retractable at a redemption amount ("Redemption Amount") of $XXXXXXXXXX per share; (iii)for the purpose of subsection 191(4) of the Act, the terms and conditions of the Class A special shares to be issued as described in paragraph 15 below will, at the time of their issue, specify $XXXXXXXXXX per share as the amount for which the share is to be redeemed, acquired or cancelled which amount will be equal to the fair market value of the property received by the particular new corporation as consideration for such share; (iv) entitled to an annual non-cumulative dividend, not to exceed xxxxxxxxxx % per annum of their Redemption Amount, to be paid at the discretion of the directors of the particular new corporation; and (v) the stated capital of these special shares will be determined on the date of issuance. 6. ...

As at XXXXXXXXXX, the following Shareholder Advances and Shareholder Loans were outstanding – a positive amount represents an amount due from the corporation to the shareholder: Mr. ...

On the Transaction Date, Child 1, Child 2, Child 3, and Child 4 will each transfer to TC1, TC2, TC3 and TC4, as the case may be, such number of DC Common Shares having an aggregate FMV equal to one-quarter of the aggregate FMV of the Transaction Assets less one-quarter of the aggregate amount outstanding on the Parent Note and Parent Note 2 (in each case, the “ TC1 Transferred Shares”, “TC2 Transferred Shares”, “TC3 Transferred Shares” and “TC4 Transferred Shares”) in the manner described in Paragraphs 20 to 24. 20. ...

XXXXXXXXXX 2021-088647 XXXXXXXXXX, 2022 Object: Income Tax Ruling – Butterfly Transactions XXXXXXXXXX Dear XXXXXXXXXX, We are writing in response to your request for an advance income tax ruling (“Ruling Request”) dated XXXXXXXXXX behalf of the above-noted taxpayers (the “Taxpayers”). ...

The DC Special Shares will have the following terms and conditions: (a) each DC Special Share will be redeemable, subject to applicable law, at any time at the option of DC at a redemption amount equal to the amount obtained by the formula (A/B x C)/D, where A equals the net FMV of the DC Real Property and the Subco Common Shares immediately before the distribution described in Paragraph 41; B equals the net FMV of all of the business property of DC immediately before the distribution described in Paragraph 41; C equals the aggregate FMV of all DC's issued and outstanding shares determined immediately before the DC share exchanges described in Paragraph 33; and D equals the number of DC Special Shares issued on the DC share exchanges described in Paragraph 33, plus any declared but unpaid dividends; (b) each DC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described in (a) above; (c) the holder of each DC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of DC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of DC if the resulting realizable value of the net assets of DC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the DC Special Shares then outstanding; (e) the holder of each DC Special Share will be entitled, upon the liquidation, dissolution or winding-up of DC, to a payment in priority to all other classes of shares of DC ranking junior to the DC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each DC Special Share will not be entitled to vote at meetings of shareholders of DC. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...