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The aggregate stated capital, paid-up capital and aggregate adjusted cost base to each shareholder of each class of issued and outstanding shares of DC are as follows: Shareholder Class # of Shares Stated Capital/PUC ACB Parent Class A- Series 1 XXXXXXXX XXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX TC 1 Class A- Series 2 XXXXXXXX XXXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX TC 2 Class A- Series 2 XXXXXXXX XXXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX Each of TC 1 and TC 2 acquired its XXXXXXXXXX Class B shares and XXXXXXXXXX Class C shares of DC on XXXXXXXXXX for cash consideration of $XXXXXXXXXX per share, respectively. ... The aggregate stated capital, paid-up capital and aggregate adjusted cost base to each shareholder, of each class of issued and outstanding shares of TC 1 are as follows: Shareholder Class # of Shares Stated Capital/PUC/ACB Sibling 1 Class A XXXXXXXXXX XXXXXXXXXX Class B XXXXXXXXXX XXXXXXXXXX Class A Preferred XXXXXXXXXX XXXXXXXXXX Sibling 1 Trust Class B XXXXXXXXXX XXXXXXXXXX 5. ... The aggregate stated capital, paid-up capital and redemption amount (where applicable) and aggregate adjusted cost base to each shareholder, of each class of issued and outstanding shares of TC 2 are as follows: Shareholder Class # of Shares Stated Capital/PUC/ACB Sibling 2 Class A XXXXXXXXXX XXXXXXXXXX Class B XXXXXXXXXX XXXXXXXXXX Class A Preferred XXXXXXXXXX XXXXXXXXXX Sibling 2 Trust Class B XXXXXXXXXX XXXXXXXXXX 7. ...

Propertyco also owns a XXXXXXXXXX % co-ownership interest (the "Interest") in XXXXXXXXXX lands, facilities and chattels and related inventories, accounts receivable and deposits (collectively, the "Facility") that Propertyco and an arm's length third party (XXXXXXXXXX, or the "Co-owner") hold as equal tenants-in-common. ... The Preference Shares will be non-voting, entitled to dividends as and when declared by the directors, redeemable and retractable at their redemption amount which will be equal to the fair market value of the consideration for which they are issued (in aggregate, the "Preference Share Redemption Amount"), bear a quarterly non-cumulative dividend equal to XXXXXXXXXX % of the Preference Share Redemption Amount and will rank ahead of the common shares as to the payment of dividends and, on a liquidation or winding-up, of the redemption amount. ... The Voting Shares will carry one vote per share, will be redeemable and retractable for their redemption amount of $XXXXXXXXXX per share and (if not already redeemed) will be entitled to receive the redemption amount on a winding-up or liquidation of New Holdco, will bear a non-cumulative annual dividend of XXXXXXXXXX % of the redemption amount, and will rank ahead of the New Preference Shares and the common shares as to the payment of dividends and, on a liquidation or winding-up, of the redemption amount. ...

None of Aco, Bco or Newco is or will be at the time of the Proposed Transactions a specified financial institution. 45.1 For all purposes of the Act, including filing its return of income or any prescribed forms, Aco will apply subsections 13 and 20 (and any regulations made for the purpose of paragraph 20(1)(a)) on the basis that the capital cost to Aco of the Trademarks acquired from Newco on the winding-up of Newco as described in Paragraph 36 will be deemed by subparagraph 13(7)(e)(ii) to be equal to the capital cost of the Trademarks to Newco before the winding-up for the same purposes, being $XXXXXXXXXX. 45.2 For all purposes of the Act, including filing its return of income or any prescribed forms, Bco will apply subsections 13 and 20 (and any regulations made for the purpose of paragraph 20(1)(a)), on the basis that the capital cost to Bco of the Trademarks acquired from Aco as described in Paragraph 39 will be deemed by subparagraph 13(7)(e)(ii) to be $XXXXXXXXXX, being equal to the aggregate of the $XXXXXXXXXX capital cost of the Trademarks to Aco, as determined under paragraph 13(7)(e), and ½ of the amount of the $XXXXXXXXXX capital gain realized by Aco on the transfer. ... The provisions of subparagraph 13(7)(e)(ii) will apply to the transfer by Bco of the Trademarks to Newco described in Paragraph 27, such that subject to subsection 70(13), for the purposes of paragraphs 8(1)(j) and (p), section 13, section 20 and any regulations made for the purpose of paragraph 20(1)(a), the capital cost of the Trademarks to Newco will be $XXXXXXXXXX, being equal to the total of the XXXXXXXXXX capital cost of the Trademarks to Bco immediately before the transfer and ½ of the amount of the $XXXXXXXXXX capital gain realized by Bco on the transfer. ... The provisions of subparagraph 13(7)(e)(ii) will apply to the transfer by Aco of the Trademarks to Bco described in Paragraph 39, such that subject to subsection 70(13), for the purposes of paragraphs 8(1)(j) and (p), section 13, section 20 and any regulations made for the purpose of paragraph 20(1)(a), the capital cost of the Trademarks to Bco will be $XXXXXXXXXX, being equal to the aggregate of the $XXXXXXXXXX capital cost of the Trademarks to Aco and ½ of the amount of the $XXXXXXXXXX capital gain realized by Aco on the transfer. ...

The issued and outstanding share capital of DC is as follows: Shareholder Class of Shares # of Shares PUC ACB Sibling 1 Common XXXX XXXX XXXX Preferred XXXX XXXX XXXX Sibling 2 Common XXXX XXXX XXXX Preferred XXXX XXXX XXXX Sibling 3 Common XXXX XXXX XXXX Preferred XXXX XXXX XXXX All of the issued and outstanding shares were issued XXXXXXXXXX. ... TC Common Shares – voting, participating, and without nominal or par value. ... TC Special Shares – non-voting, non-participating (beyond the redemption amount) and redeemable and retractable for a redemption amount equal to the FMV of the property transferred to the TC in consideration for the issuance of these shares. 11. ...

"XXXXXXXXXX Property" means the XXXXXXXXXX percent (XXXXXXXXXX %) joint venture interest that DC owns in land inventory located at XXXXXXXXXX. ... DC owns XXXXXXXXXX % of the issued and outstanding shares of Subco5. The other shareholders of Subco5 deal at arm's length with DC. ... This amount represents fifty percent (XXXXXXXXXX %) of the FMV of TC1, TC2 and TC3 as the case may be. ...

Les actions de catégorie « B » seront non votantes, non participantes et donneront droit à un dividende mensuel et non cumulatif au taux, tel que déterminé par le conseil d'administration, variant de XXXXXXXXXX à XXXXXXXXXX % de la valeur de rachat. ... Les actions de catégorie « C » seront non votantes, non participantes et donneront droit à un dividende mensuel et non cumulatif au taux, tel que déterminé par le conseil d'administration, variant de XXXXXXXXXX à XXXXXXXXXX % de la valeur de rachat. ... Les actions de catégorie « D » seront non votantes, non participantes et donneront droit à un dividende mensuel et non cumulatif au taux, tel que déterminé par le conseil d'administration, variant de XXXXXXXXXX à XXXXXXXXXX % de la valeur de rachat. ...

The assets of the joint venture, in which DC held a XXXXXXXXXX % share, were comprised of cash, an equity balance with the XXXXXXXXXX, receivables, prepaid insurance and a parcel of real estate consisting of land and buildings located at XXXXXXXXXX. ... On XXXXXXXXXX, DC agreed to sell its XXXXXXXXXX % interest in the assets of the joint venture and the shares it held in XXXXXXXXXX. to the other participants in the joint venture, XXXXXXXXXX. ... The sale of the XXXXXXXXXX % interest in the assets of the joint venture and the shares of XXXXXXXXXX. was done entirely for business reasons and was not done in contemplation of the proposed butterfly distribution by DC. ...

LP#1 holds a XXXXXXXXXX % limited partnership interest in each of LP#3, LP#2 and LP#6. ... GP Corp holds one Class A unit of LP#1, one Class A unit of LP#5 and a XXXXXXXXXX % partnership interest in each of LP#2, LP#3 and LP#6. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The First Nation will be the sole contributor of funds to the trust, and is the sole beneficiary (?) ... Canada asserted that the First Nations were "XXXXXXXXXX ", at the time of this surrender in XXXXXXXXXX. 8. ... As stated in the "XXXXXXXXXX " signed at the XXXXXXXXXX on XXXXXXXXXX, the First Nation claimed: XXXXXXXXXX. 12. ...

The Trust will continue until terminated by a vote of the Members to terminate the trust in which not less than XXXXXXXXXX% of the Members entitled to vote cast a vote and not less than XXXXXXXXXX % vote to approve the termination of the Trust, provided that Canada has at the date of the vote set land aside as Reserve for XXXXXXXXXX in an amount not less than XXXXXXXXXX % of the XXXXXXXXXX acres of land to which XXXXXXXXXX is entitled under the Treaty Entitlement Agreement. 64. Upon termination of the Trust, the Trust Property then remaining will be transferred to XXXXXXXXXX and will be applied by XXXXXXXXXX as determined by a vote in which not less than XXXXXXXXXX% of the Members entitled to vote cast a vote and not less than XXXXXXXXXX % vote to approve of the application of the Trust Property. 65. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...