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The issued and outstanding share capital of DC consists of XXXXXXXXXX common shares ("DC Common Shares"), which are owned by the following persons: DC Common Shares ACB $ XXXXXXXXXX. ... Prior to the Amalgamation of Parentco, ACo and BCo, (a) all of the common shares of Parentco were owned by XXXXXXXXXX ("Individual D") and his spouse XXXXXXXXXX ("Individual E") and a corporation XXXXXXXXXX ("CCo"), which dealt at arm's length with Individuals D and E, as follows: (i) Individual D XXXXXXXXXX (ii) Individual E XXXXXXXXXX (iii) CCo XXXXXXXXXX XXXXXXXXXX (b) Parentco owned all of the issued and outstanding shares of BCo and approximately XXXXXXXXXX % of the issued and outstanding shares of ACo. ... Immediately after the share exchanges described in this paragraph, the aggregate FMV of the TC Common Shares owned by the particular DC shareholder will be equal to or approximate the amount determined by the formula, on the assumption that Holdco, Individuals A, B and C are participants, DC is the distributing corporation and TC is the acquirer, A x B + D C as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

LP 2 has a XXXXXXXXXX % partnership interest in Partnership A which purchases and then sells all of Bco's production; (c) XXXXXXXXXX% of the common shares of Cco. ... This XXXXXXXXXX % interest in Aco would approximate a XXXXXXXXXX% indirect equity interest in LP 1 and a XXXXXXXXXX % indirect equity interest in Bco. ...

These aggregate proceeds are comprised of $XXXXXXXXXX in respect of the issuance of Class A Units (XXXXXXXXXX Class A Units x $XXXXXXXXXX), $ XXXXXXXXXX in respect of collateralized interest for the first XXXXXXXXXX period of the Unit Loans and $ XXXXXXXXXX being the aggregate Loan Arrangement Fee payable to Canco #2. ... The interest rate from the date of the advance until the date that is XXXXXXXXXX after the date of the advance shall be XXXXXXXXXX% and thereafter will be reset at a rate which is, on such date, equal to the greater of the prime bank rate plus XXXXXXXXXX % and the prescribed rate of interest for the purposes of section 143.2 of the Act. ...

The Corporation DSU Plan is the subject of advance income tax rulings #970236 dated XXXXXXXXXX, 1997 and # 2000-0004163 dated XXXXXXXXXX, 2000. The Subsidiary DSU Plan is the subject of advance income tax rulings #971577 dated XXXXXXXXXX, 1997 and # 2000-0004153 dated XXXXXXXXXX, 2000. 10. ... The Participant will receive the remainder (if any) of his or her compensation (i.e., meeting, committee and committee chairman fees) in cash net of applicable withholdings; (d) All Participants under the Subsidiary DSU Plan who have entered into an agreement and made elections in accordance with the terms of that plan shall be deemed to have entered into an Agreement and to have made elections under the Master DSU Plan for the XXXXXXXXXX and subsequent calendar years (unless such elections are revoked or modified by the Participant) as if the agreement and elections entered into and made under the Subsidiary DSU Plan had been entered into and made under the Master DSU Plan; (e) With respect to the XXXXXXXXXX and subsequent calendar years, each Participant who is a director of a Corporation Entity and who shall not be deemed to have elected in accordance with 13(d) above, or who was deemed to have so elected but has modified or revoked that election, may elect to be paid up to XXXXXXXXXX % of his or her annual retainer fee (and, if allowed by the Committee, fees other than the annual retainer fee such as meeting and committee fees described in 8(b), (c) and (d) above) paid by such Corporation Entity in the form of Share Units under the Master DSU Plan in lieu of being paid in cash. ...

., for example, plainly says "... it makes no real difference in substance or as to the nature of the payments whether they arise through a "reservation", strictly so called, or a covenant. ... Commissioners of Inland Revenue, "the fact that people who, after all, now all about it, choose in their agreement to refer to these annual sums *** as "royalties", is a matter not to be entirely neglected". ... Gregory & Co. 196 1 Q. B., 147; B. L. Grain Ltd. v. Ashton et al (1949) or 303). ...

The subject matter to be covered was divided into three parts: • Part One: Principles and methods • Part Two: Applications • Part Three: Specific subjects (e.g. permanent establishment) The report's revised Part One, containing the most important subject matter, was published in the summer of 1994 for comments by members of the public; the final version was published in July of 1995. ... There has been no radical change in recognition and classification of the various methods — the superiority of methods based on transaction values is reaffirmed. ...

Such right to a dividend shall be forever extinguished XXXXXXXXXX months after the expiration of any financial year of DC; (v) the Class E preferred shares are entitled to non-cumulative preferential dividends from XXXXXXXXXX per cent (XXXXXXXXXX%) up to a maximum of XXXXXXXXXX per cent (XXXXXXXXXX %) per annum on the capital amount paid up on each Class E preferred share in priority of any other shares of DC, except Class A preferred shares, Class B preferred shares, Class C preferred shares and Class D preferred shares. ... XXXXXXXXXX Class D preferred shares which are held by XXXXXXXXXX (the "Trust D"), with an aggregate PUC of $ XXXXXXXXXX and an aggregate ACB of $XXXXXXXXXX; b. ... The aggregate FMV and redemption value of the shares of DC is as follows: a. the Common shares have an aggregate FMV of $XXXXXXXXXX; b. the Class A preferred shares have a redemption value of $XXXXXXXXXX; c. the Class B preferred shares have a redemption value of $XXXXXXXXXX; d. the Class C preferred shares have a redemption value of $XXXXXXXXXX; e. the Class D preferred shares have a redemption value of $XXXXXXXXXX; f. the Class E preferred shares have a redemption value of $XXXXXXXXXX; g. the Class F preferred shares have a redemption value of $ XXXXXXXXXX; 12. ...

XXXXXXXXXX is a taxable Canadian corporation, which is subject to the CBCA, of which XXXXXXXXXX owns XXXXXXXXXX shares forming XXXXXXXXXX % of its share capital. ... XXXXXXXXXX is a U.S. public company which owns approximately XXXXXXXXXX % of the equity of XXXXXXXXXX. 30. ... XXXXXXXXXX will transfer the following properties (collectively, the " XXXXXXXXXX Properties") to Newco 1:- all of its XXXXXXXXXX equipment included in Class 8 and Class 17 pursuant to Schedule II of the Regulations;- all of its XXXXXXXXXX included in Class 8 and XXXXXXXXXX pursuant to Schedule II of the Regulations; and- such part of those assets which would otherwise be included in the assets described in (i) and (ii) above which are not currently available for use pursuant to subsection 13(26), referred to as "assets not currently available for use". 55. ...

& Class ACB PUC FMV Voting D XXXX B $XXX $XXX $XXX Yes A Holdco XXXX A1 $XXX $XXX $XXX No B Holdco XXXX A2 $XXX $XXX $XXX No C Holdco XXXX A3 $XXX $XXX $XXX No 10. ... & Class ACB PUC FMV Voting C Holdco XXXX A3 $XXX $XXX $XXX No XXXX F3 $XXX $XXX $XXX No B Holdco XXXX A2 $XXX $XXX $XXX No XXXX F2 $XXX $XXX $XXX No A Holdco XXXX A1 $XXX $XXX $XXX No XXXX F1 $XXX $XXX $XXX No D Holdco XXXX X1 $XXX $XXX $XXX No D XXXX B $XXX $XXX $XXX Yes XXXX X $XXX $XXX $XXX No Total: $XXX 13. ... Upon CCo’s incorporation, the following entities and individuals will subscribe for the following shares in CCo: Shareholder No & Class Subscription Voting Price GP XXXX C2 $XXXX Yes D XXXX C1 $XXXX Yes XXXX X $XXXX No D Holdco XXXX X1 $XXXX No 34. ...

On XXXXXXXXXX, XXXXXXXXXX announced that less than the required XXXXXXXXXX % of the XXXXXXXXXX shares had been tendered to XXXXXXXXXX 's Offer and that XXXXXXXXXX had elected to permit the Offer to expire XXXXXXXXXX. ... On XXXXXXXXXX, XXXXXXXXXX successfully acquired XXXXXXXXXX % of the shares of XXXXXXXXXX that it did not already own. ...