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To the best of Buyerco's knowledge, the XXXXXXXXXX largest common shareholders of Buyerco immediately before XXXXXXXXXX were: Shareholder % XXXXXXXXXX XXXXXXXXXX In XXXXXXXXXX acquired ownership of the shares of the capital stock of Buyerco owned by XXXXXXXXXX XXXXXXXXXX was the registered owner of approximately XXXXXXXXXX % of the shares of the capital stock of Buyerco and held these shares for various investors who, through brokerage firms or other investment firms, were the beneficial owners of the said shares. 3. ... To the best of Target's knowledge, the XXXXXXXXXX largest common shareholders of Target immediately before XXXXXXXXXX were: Shareholder % XXXXXXXXXX XXXXXXXXXX To the best of Target's knowledge, the XXXXXXXXXX largest common shareholders of Target XXXXXXXXXX: Shareholder % XXXXXXXXXX XXXXXXXXXX The above shareholding information was obtained from the non-objecting beneficial owners ("NOBO") lists of Target shares. ... On XXXXXXXXXX, BuyerSubco III purchased XXXXXXXXXX shares of the capital stock of Target owned by VendorSubco I, representing approximately XXXXXXXXXX % of the then XXXXXXXXXX shares of the capital stock of Target. ...

.), as amended to the date hereof and unless otherwise stated, every reference to a Part, section, subsection, paragraph, subparagraph or clause is a reference to the relevant provision of the Act; "affiliated" has the meaning assigned by subsection 251.1(1); "Amalco" means the corporation to be formed on the amalgamation of the Corporations; "Board" means the board of Directors of a Corporation; "C1" means XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "C2" means XXXXXXXXXX; XXXXXXXXXX; "Corporations" means C1 and C2, and "Corporation" means any one of them; "CRA" means the Canada Revenue Agency; "Director" means a director of a Corporation; "Fund" means a portfolio of investments held by a Corporation that correlates to one or two specific classes of shares issued by the Corporation and is subject to regulation as a mutual fund under Canadian securities legislation; "GAAR" means the general anti-avoidance rule in subsection 245(2); "Manager" means XXXXXXXXXX; "Mutual Fund Shares" means shares of a Corporation issuable in series that are of a class other than voting common shares; "NI 81-102" means National Instrument 81-102 – Mutual Funds; "NI 81-107" means National Instrument 81-107 – Independent Review Committee for Investment Funds"; "related" has the meaning assigned by subsection 251(2); XXXXXXXXXX; and XXXXXXXXXX. ...

During these months, approximately XXXXXXXXXX % of the XXXXXXXXXX Facility was used XXXXXXXXXX in the Club's XXXXXXXXXX 8. The income from XXXXXXXXXX represents approximately XXXXXXXXXX % of the Club's gross revenue. ...

2005 Ruling 2005-0133041R3- Investors not dealing non-arm's length Unedited CRA Tags 248(1) taxable Canadian property 251(1)(c) Principal Issues: Whether Investors that collectively own XXXXXXXXXX % of a Canadian corporation are "acting in concert", and therefore not at arm's length when they wind up the structure in order to sell the shares? ... Yours truly, XXXXXXXXXX Acting Section Manager International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch XXXXXXXXXX ...

A term of the offer to purchase was that the Association accept a tenant, XXXXXXXXXX, that would occupy approximately XXXXXXXXXX % of the building. ... The Association will use the remaining XXXXXXXXXX % of the property to house its offices and for storage space. 11. ...

Le capital-actions émis et en circulation de XXXXXXXXXX immédiatement avant les opérations envisagées se résume comme suit: Actionnaires Nombre d'actions Pourcentage de la participation (%) XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 10. ... Suite à ce transfert d'actions de XXXXXXXXXX à XXXXXXXXXX, le capital-actions émis et en circulation de XXXXXXXXXX s'établira comme suit: Actionnaires Nombre d'actions Pourcentage de la participation (%) XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 14. ...

Will Mrs A be considered to have received fmv proceeds where income interest is released with no direction & for no consideration? ... See IT-385R2 & previous rulings; 2. previous position maintained; 3. previous positions applicable; 4. trust is a spousal trust-107(4) not 107(2) is applicable XXXXXXXXXX 2005-011301 XXXXXXXXXX, 2005 Dear XXXXXXXXXX Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above noted estate, trust and beneficiaries under the trust in respect of the income tax consequences arising out of the proposed transactions described below. ...

The issued shares of Ltd are held as follows: # PUC ACB FMV Class B non-voting, retractable special shares XXXXXXXXXX XXXXXXXXXX Common shares XXXXXXXXXX XXXXXXXXXX 3. ... Its share structure is as follows: Common shares # PUC ACB FMV XXXXXXXXXX 6. ...

FA 1 holds XXXXXXXXXX% of a class of issued and outstanding par value shares of FA 2 (the "FA 2 Shares") and Canco's equity percentage in respect of FA 2 is XXXXXXXXXX %. ... Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

The Promissory Note bears interest at XXXXXXXXXX % per annum for the first XXXXXXXXXX years. ... At present, D Co incurs all the interest expense on the $XXXXXXXXXX Promissory Note but only earns XXXXXXXXXX % of the XXXXXXXXXX Partnership revenue. ...