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The aggregate FMV, immediately before Distribution 1, of the Non-Canadian DC 1 Common Shares owned by Forco 3 will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Forco 3 is the participant, Canadian DC is the distributing corporation and Non-Canadian DC 1 is the acquiror. ... The aggregate FMV, immediately before Distribution 2, of the Non-Canadian DC 2 Common Shares owned by Forco 3 will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Forco 3 is the participant, Canadian DC is the distributing corporation and Non-Canadian DC 2 is the acquiror. ... The aggregate FMV, immediately before the transfer of property by Non-Canadian DC 2 to Foreign Spinco2-Sub described in Paragraph 117, of the Non-Canadian DC 2 Common Shares owned by Foreign Pubco will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Pubco is the participant, Non-Canadian DC 2 is the distributing corporation and Foreign Spinco 2 is the acquiror. ...

As at XXXXXXXXXX, HOLDCO 3’s assets consist of cash, accounts receivable, deposits & prepaid expenses, mortgage assumption fees and revenue-producing property. ... HOLDCO 4 has the following amounts in its tax accounts (estimated as of XXXXXXXXXX): RDTOH- XXXXXXXXXX; GRIP – XXXXXXXXXX. 29. ... A had sole decision making authority over all XXXXXXXXXX % owned corporation until the time of his death and was a director of the corporations. ...

The decision to pay the other XXXXXXXXXX % of the liabilities was made as part of the process of planning the sale as the shareholders had agreed to pay off such liabilities at the time they agreed to sell the XXXXXXXXXX. ... DC paid a capital dividend on XXXXXXXXXX of approximately XXXXXXXXXX % of the proceeds received from the XXXXXXXXXX sale of XXXXXXXXXX. ... The DC special shares will be non-voting, and entitled to a non-cumulative dividend at the rate of XXXXXXXXXX % of the redemption amount. ...

Pubco 1 received in consideration approximately $XXXXXXXXXX in cash and XXXXXXXXXX shares of Pubco 2, which at the time of the sale represented a XXXXXXXXXX % shareholding interest in Pubco 2. ... Pubco 1 acquired approximately XXXXXXXXXX % of the issued and outstanding shares in Pubco 2 on the First Transfer, which percentage has now been reduced to approximately XXXXXXXXXX %. ... The fair market value, immediately before the transfer of the Spin-off Property described in Paragraph 12, of each Participant's shares of the capital stock of Newco will be equal to the amount determined by the formula: (A x B/C) + D as set out in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 12. ...

XXXXXXXXXX 2017-073301 XXXXXXXXXX, 2018 Dear XXXXXXXXXX, Re: Advanced Income Tax Ruling XXXXXXXXXX collectively referred to as the « Taxpayers » We are writing in response to your request for an advance income tax ruling. ...

Provided that immediately after the Proposed Transactions REIT # 1 shall own all of the assets that the Taxpayer previously owned, directly or indirectly, immediately before the Proposed Transactions, the provisions of subsections 15(1), 56(2), 56(4), 69(1), 69(4), 105(1) and 246(1) of the Act will not apply as a result of the Proposed Transactions, in and by themselves. ... In particular, * we express no opinion with respect to whether Trust A, the Direct Subtrusts, OT, Target, Target Operating Trust, REIT #1, REIT #2, REIT #3, or REIT #4 is a mutual fund trust within the meaning of subsection 132(6) of the Act at any particular time; * we express no opinion with respect to whether Trust A, Target, REIT #1, REIT #2, REIT #3, or REIT #4 is a unit trust at any particular time; * we express no opinion with respect to whether the Taxpayer is a mutual fund corporation within the meaning of subsection 131(8) of the Act at any particular time; * we express no opinion with respect to whether the Target unitholders could elect under section 85 of the Act, as referred to in 19 above; * we have made no determination of the fair market value of any property referred to herein; * we have made no determination of the amount of any capital gain referred to herein; and * we express no views as to any tax consequences relating to the facts and proposed transactions described herein other than those described in the rulings and opinions provided above. ...

Position: 1 – Yes; 2- This is an audit issue but we ruled favorably provided it meets the CRP definition; 3- No. ... The issued share capital of Subco consists of: XXXXXXXXXX common shares, with a PUC of approximately $XXXXXXXXXX; XXXXXXXXXX Series A first preferred shares, with a PUC of approximately $ XXXXXXXXXX; XXXXXXXXXX Series B first preferred shares with a PUC of approximately $ XXXXXXXXXX; and XXXXXXXXXX Series C preferred shares with a PUC of approximately $ XXXXXXXXXX. ...

The revised proposal is to retain the limited partnership with the taxpayer as the general partner having a XXXXXXXXXX % interest and its newly created wholly-owned subsidiary as the sole limited partner having a XXXXXXXXXX % interest. ... The interest on the Tranche A Loan will be XXXXXXXXXX % per annum. The Restated Term Loan Agreement will provide for equal monthly blended payments of principal and interest to fully amortize the Tranche A Loan prior to its maturity date of XXXXXXXXXX. b) As a condition precedent, a repayment of $XXXXXXXXXX on account of accrued and unpaid interest on the Term Loan was made on XXXXXXXXXX prior to the entering into of the Debt Restructuring Agreement. ... The Tranche B Loan will mature on XXXXXXXXXX. c) The Term Lenders will be issued Tranche A Secured Senior Term Notes and Tranche B Secured Senior Term Notes on a pro-rata basis in replacement for the Secured Senior Term Notes issued to evidence the Term Loan to the Term Lenders. d) To the extent that the Tranche B Loan is repaid in full prior to its maturity date and there are sufficient funds available at the appropriate level of the "waterfall" referred to in 57 below, the Tranche B Lenders will be paid a fee (the "Restructuring Fee") in an amount equal to the amount which is required to bring the internal rate of return on the Tranche B Loan to the Tranche B Lenders to XXXXXXXXXX % per annum for the period from and including XXXXXXXXXX to the date on which the last instalment of the Restructuring Fee is paid. ...

The terms of the Settlement Agreement provide, among other matters, for payment for the benefit of the Plaintiff of lifetime monthly payments of $XXXXXXXXXX, indexed at a rate of XXXXXXXXXX % per annum, compounded, commencing on XXXXXXXXXX (the "Structure Payments"), which Structure Payments are guaranteed to be made through XXXXXXXXXX in the event of the Plaintiff's death prior to that date. 6. ...

The terms of the settlement provide for periodic payments to or for the benefit of the Plaintiff consisting of lifetime monthly payments of $XXXXXXXXXX commencing XXXXXXXXXX indexed at a rate of XXXXXXXXXX % per year, compounded. ...