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Father will transfer to S1 Holdco XXXXXXXXXX % of the Class D voting preferred shares of Holdco 4 to S1 Holdco in exchange for cash in an amount equal to the redemption and retraction price and fair market value of the Class D voting preferred shares. ...

Alternatively, paragraph 12(1)(b) of the Act could be invoked, as specified in section 5 of Interpretation Bulletin IT-170R: "... it is the Department's view that the sale price of any property sold is brought into account for income tax purposes when a vendor has an absolute but not necessarily immediate right to be paid. ...

" means XXXXXXXXXX "Production Services Partnership" means XXXXXXXXXX, as described in 2 below; "Production Services Partnership Agreement" means the limited partnership agreement governing the affairs of the Production Services Partnership made among PSGP, an initial limited partner, each Class A Unitholder and each Class B Unitholder of the Production Services Partnership, from time to time; "Programs" means the following programs intended to be produced in Canada XXXXXXXXXX; "PSGP" meansXXXXXXXXXX, the general partner of the Productions Services Partnership described in 2 below; "PSP Fee" means the fee payable by the Production Services Partnership to PSGP under the Production Services Partnership Agreement for the management and administrative services provided by the PSGP as described in 2 below; "Regulations" means the regulations made under the Act; "Release Date" means the date (to be negotiated) by which the Studio or its appointed distributor is to release or distribute the Programs for commercial exploitation; "Studio" means XXXXXXXXXX as described in 4 below; "Studio/Producer Loan" means the loan made by the Studio to the Producer as described in 18 below; "Subscription Agreement" means each subscription agreement pursuant to which an Investor will acquire Units of the Offering Partnership; "Tax Credits" means the film and video production services tax credits that are available pursuant to section 125.5 of the Act and the corresponding film and video production services tax credits that are available under provincial legislation in respect of certain salary, wage and remuneration expenses incurred in Canada in relation to the production of a film or video; "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; "Undistributed Cash" means any cash retained on hand by the Production Services Partnership or any amount due to the Production Services Partnership as unpaid subscription price; "Unit" or "Units" means a unit or units of the Offering Partnership; "Unit Lender" means the XXXXXXXXXX described in 7 below; "Unit Loan" means a loan to be made available to each Investor pursuant to which the Unit Lender will lend, and an Investor will borrow, an amount to finance approximately XXXXXXXXXX% of the subscription price for an Investor's Units; "Unit Loan Agreement" means the unit loan agreement to be executed between the Unit Lender and an Investor, as described in 23 below; and "Unit Subscription Price" means the amount paid by a subscriber to the Offering Partnership to acquire a unit of the Offering Partnership. ...

FORCO 1 and FORCO 2 will subsequently transfer their respective common shares of Canco and, accordingly, the underlying Canadian XXXXXXXXXX business, to IPO Co so that IPO Co can make a public offering in respect thereof of up to XXXXXXXXXX % of the shares of its capital stock. ...

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

The taxation year-end of each taxpayer referred to herein; their social insurance number or tax account number, tax service office ("TSO") or taxation centre ("TC") of Revenue Canada at which each such taxpayer files its income tax return (TSO/TC) and the approximate amounts of the capital dividend account and refundable dividend tax on hand of each such corporate taxpayer at the end of its 1998 taxation year are set forth below: Taxpayer and (SIN/Account #) TSO/TC Year-End RDTOH CDA DC (XXXXXXXXXX) XXXXXXXXXX ABco (XXXXXXXXXX) XXXXXXXXXX Bco (XXXXXXXXXX) XXXXXXXXXX Asub (XXXXXXXXXX) XXXXXXXXXX Aco (XXXXXXXXXX) XXXXXXXXXX Cco (XXXXXXXXXX) XXXXXXXXXX Spousal Trust Ltd. ...

+ D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

Z XXXXXXXXXX /PUBCO XXXXXXXXXX shares XXXXXXXXXX Trust * XXXXXXXXXX/PUBCO XXXXXXXXXX shares XXXXXXXXXX (XXXXXXXXXX /Mr. ...

On a particular day in late XXXXXXXXXX, each of Newlossco3 and Newlossco4 will issue demand notes payable, bearing interest at a rate of XXXXXXXXXX %, the Newlossco3 Note A and Newlossco4 Note A, respectively, to Opco for cash in the amount of the non-capital losses of each of Newlossco3 and Newlossco4 at that time (which will approximate the interest expense incurred by each of Newlossco3 and Newlossco4 on the Newlossco3 Note and Newlossco4 Note, respectively). 47. ...

XXXXXXXXXX 2021-089667 XXXXXXXXXX Dear XXXXXXXXXX, Re: Advance Income Tax Ruling – Sequential butterfly reorganizations XXXXXXXXXX (Collectively referred to as the “Taxpayers”) We are writing in response to your request for an advance income tax ruling (“Ruling request”) dated XXXXXXXXXX, and revised on XXXXXXXXXX, on behalf of the above-noted Taxpayers. ...