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Summary of Intertain Circular under Public Transactions – Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Exchangeable Shares. ...

Agence du revenu du Québec, 2021 QCCQ 4379 under Reg. 1206(1) – CEDOE – para. (b), s. 18(1)(b) – capital expenditure v. expense – current expense v. capital acquisition, s. 66.1(6) – CEE – para. ...

Summary of Clementia Pharmaceuticals Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Canadian Buyco. ...

When asked about the implications of this decision, CRA first indicated that “the court applied the three consecutive week requirement to the summer semester as a whole, rather than to each individual course in the semester,” and then stated: Our interpretation of subparagraph 118.5(1)(b)(i) … as explained in paragraph 2.10 of … S1-F2-C2 … has generally not changed as a result of … Fortnum. … [T]his case was heard … under the Informal Procedure … [and] do[es] not have precedential value. ...

CRA noted that ATI is determined by the formula A + B – C, and A is determined by the formula D – E. with variable D in general terms referring to the taxpayer’s taxable income for the year determined without regard to s. 18.2(2). ... Summary of 3 December 2024 CTF Roundtable, Q.5 under s. 18.2(1) – ATI – A – D(b). ...

., standby charges) payable by a borrower as consideration for the lender agreeing to lend money or make money available (arguably, under the definition of “restrictive covenant” such an agreement “affects … the … provision of property … by the taxpayer” (i.e., of funds by the lender) or “affects … the acquisition of property … by the taxpayer” (i.e., the lender’s acquisition of the debt obligation)) consent payments to creditors, e.g., to permit a particular transaction or loosen a financial covenant (such “agreement could be viewed as affecting the (ongoing) provision of property by the taxpayer, being the loaned funds, especially if the consent relates to an amendment of a covenant that could otherwise have been breached and allowed … acceleration …”) in the context of a distress restructuring, an additional payment made to a debt holder who agrees to exchange for the securities of the restructured debtor by a specified date, e.g., the receipt of additional shares on a debt for shares restructuring (the additional shares “may properly be viewed as consideration for the debenture holder having agreed to consent to the restructuring plan by the specified date, rather than as consideration for the exchange itself, having regard to paragraph 68(c).”) ...

Summaries of Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission under s. 18.2(1)- IFR, s. 80(2)(b), s. 18.2(1) – excluded entity – (c), s. 18.2(1) – tax-indifferent, s. 18.2(1) – ATI – C – (a), s. 18.2(1) – excluded lease, s. 183.3(1) – substantive debt – (c), s. 183.3(2), s. 55(5)(e), s. 93.4(1) – FABI, s. 220(3.2), s. 191.1(1) – excluded dividend, and s. 12(13)(b). ...

22 August 2017- 12:41am Tembec is to be acquired by Rayonier AM or a sub of Rayonier AM for 2/3 cash and 1/3 Rayonier AM shares Email this Content Tembec, which is a TSX-listed CBCA corporation, agreed to a CBCA Plan of Arrangement with NYSE-listed Rayonier AM under which its (common) shares were to be acquired by Rayonier AM for consideration (at each Tembec shareholder’s option) of C$4.75 cash or 0.2542 of a Rayonier AM common share – except that proration would occur so as to result in the overall consideration being more or less fixed at 67% cash and 33% shares. ... Summary of Tembec Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Canadian Buyco. ...

., gains realized by the Bermuda LP) rather than as gains giving rise to FAPI, management did not anticipate that the special distribution included any ordinary income – so that it was expected that the unitholders received the same treatment as if they had sold their Units for cash. ... Summary of Dream Global REIT Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – REIT Targets. ...

Offer under Public Transactions – Mergers & Acquisitions – Unsolicited Bids. ...