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In order to facilitate the proposed distribution described in Paragraph 24, DC will cause some or all of the real property described as XXXXXXXXXX to be severed in equal (XXXXXXXXXX %) interests. 17. ... DC will transfer its legal title (but not beneficial ownership) to the XXXXXXXXXX, a XXXXXXXXXX % severed interest in the XXXXXXXXXX, a XXXXXXXXXX% severed interest in the XXXXXXXXXX, a severed interest in XXXXXXXXXX (hereinafter referred to as the "Trusteed Real Property") to Bare Trusteeco. ...

(iv) Notwithstanding anything in the Plan to the contrary, for Tradable Options granted on or after XXXXXXXXXX, if a Canadian Participant's employment with all members of the Group is terminated by reason of death, disability or retirement (as approved by the Committee for Tradable Options granted on or after XXXXXXXXXX) prior to the end of the Option Period, the Tradable Option shall become XXXXXXXXXX % vested and non-forfeitable and shall expire on XXXXXXXXXX of the Option Period. (v) Notwithstanding anything in the Plan to the contrary, for Tradable Options granted on or after XXXXXXXXXX, if a Canadian Participant's employment with all members of the Group is terminated by reason of normal termination, and within XXXXXXXXXX days of such normal termination the Canadian Participant becomes disabled, the Tradable Options shall become XXXXXXXXXX % vested and non-forfeitable and shall expire on the last day of the Option Period. ...

All of the issued and outstanding shares in the capital of Canco are held by Holdco 1, Holdco 2 and Holdco 3 as follows: Shareholder Number of shares Redemption amount Voting % XXXXX Class A $XXXXX per share XXXXX% Holdco 1 preferred (redemption amount) (one vote per XXXXX Class B $XXXXX per share share) preferred (redemption amount) Holdco 2 XXXXX common- XXXXX% (one vote per share) Holdco 3 XXXXX common- XXXXX% (one vote per share) 4. ... A, who hold the following number of shares: Shareholder Number of shares Redemption amount Voting % XXXXX common XXXXX% Mr. ...

Its issued and outstanding share capital consists of: a) XXXXXXXXXX Class B voting, redeemable shares, entitled to a XXXXXXXXXX % non-cumulative dividend; b) XXXXXXXXXX Class D non-voting, redeemable and retractable shares, entitled to a XXXXXXXXXX % non-cumulative dividend; c) XXXXXXXXXX Class E voting common shares. ...

At that time, the applicable foreign currency exchange rate was US$1 = CDN$XXXXXXXXXX and the Canadian dollar equivalent of US$XXXXXXXXXX was CDN$XXXXXXXXXX; and (b) On XXXXXXXXXX, XXXXXXXXXX Co issued further Public Notes having an aggregate Principal Amount of US$XXXXXXXXXX. At that time, the applicable foreign currency exchange rate was US$1 = CDN$XXXXXXXXXX and the Canadian dollar equivalent of US$XXXXXXXXXX was CDN$XXXXXXXXXX. 9. ...

On XXXXXXXXXX, DC completed the sale of a XXXXXXXXXX% interest in the "XXXXXXXXXX " property located in the XXXXXXXXXX area to XXXXXXXXXX. for consideration consisting of XXXXXXXXXX common shares of XXXXXXXXXX. ... The fair market value, immediately before the transfer described in Paragraph 26 below, of each Participant's shares of the capital stock of Spinco 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 "permitted exchange" in subsection 55(1). ...

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. ...

Each Holdco will have authorized share capital as follows: (a) Class A preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (b) Class B preference shares: voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (c) Class C preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (d) Class D preference shares: non-voting; non-participating; cumulative monthly dividends at a rate equal to XXXXXXXXXX% of the prime rate; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (e) Class E preference shares: issuable in series with terms and conditions (including dividend entitlement at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum) to be determined by the directors upon filing of articles of amendment; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; (f) Class F preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (g) Class G preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX % to XXXXXXXXXX % per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (h) Class H preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (i) Class I preference shares: non-voting; non-participating; non-cumulative dividends (in the form of capital dividends) equal to the increase in the capital dividend account from life insurance proceeds upon death of a holder of Class I Preference shares; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable upon death of a holder, retractable and may be purchased for cancellation for their redemption amount (generally at $XXXXXXXXXX per share); (j) Class J preference shares: non-voting; non-participating; non-cumulative dividends in amounts determined by the directors; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount (generally at $XXXXXXXXXX per share); (k) Class K preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to a maximum of CCRA's prescribed rate per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (l) Class L preference shares: non-voting; non-participating; non-cumulative dividends at a rate equal to XXXXXXXXXX% of CCRA's prescribed rate per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount; (m) Class M preference shares: non-voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable, retractable and may be purchased for cancellation for their redemption amount (generally at $XXXXXXXXXX per share); (n) Class V preference shares: voting; non-participating; non-cumulative dividends at variable rates from XXXXXXXXXX% to XXXXXXXXXX% per annum; ranked XXXXXXXXXX upon dissolution, liquidation or wind-up; redeemable upon death or insolvency of a holder, retractable and may be purchased for cancellation for their redemption amount; (o) Class A common shares: voting; participating; non-cumulative dividends in amounts determined by the directors; right to remaining property upon dissolution, liquidation or wind-up pari passu with Class B, Class C and Class D Common shares; (p) Class B common shares: non-voting; participating; non-cumulative dividends in amounts determined by the directors; right to remaining property upon dissolution, liquidation or wind-up pari passu with Class A, Class C and Class D Common shares; (q) Class C common shares: voting; participating; non-cumulative dividends in amounts determined by the directors; no entitlement to capital dividends; right to remaining property upon dissolution, liquidation or wind-up pari passu with Class A, Class B and Class D Common shares; and (r) Class D common shares: voting; participating; non-cumulative dividends in amounts determined by the directors; right to remaining property upon dissolution, liquidation or wind-up pari passu with Class A, Class B and Class C Common shares. ...

(e) XXXXXXXXXX an inactive U.S. corporation incorporated under the laws of the State of XXXXXXXXXX owns XXXXXXXXXX % of the outstanding shares of XXXXXXXXXX. ... XXXXXXXXXX is a holding company and owns XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX is a U.S. corporation incorporated under the laws of the State of XXXXXXXXXX carries on the XXXXXXXXXX business in the U.S. for the Opco Group. 10. ...

XXXXXXXXXX The XXXXXXXXXX Partnership will be responsible for expenses related to the XXXXXXXXXX Services that form part of the XXXXXXXXXX Services budget (the "XXXXXXXXXX Expenses"), including any reimbursements (the "XXXXXXXXXX ") of amounts expended by the XXXXXXXXXX on account of the XXXXXXXXXX Fee (as described in Paragraph 38). ... Aco will agree to pay the XXXXXXXXXX Facilitator a Product Procurement Facilitation Fee equal to approximately XXXXXXXXXX % of the XXXXXXXXXX Expenses. ...