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DC1 will hold the XXXXXXXXXX % undivided interest in Property2, Property3, Property4 and the Subco shares, if any, received by it from DC2 as capital property. 16. Contemporaneously with the transfer of property described in paragraph 15 above, DC3 will transfer to DC1 at fair market value all of its properties, including its XXXXXXXXXX % undivided interest in each of Property1, Property2 and Property3. ...

The approximate FMV of the assets of DC on XXXXXXXXXX are as follows: Assets FMV ($) Cash XXXXX Cash surrender value of life insurance policy XXXXX Marketable Securities XXXXX Total XXXXX The approximate FMV of the liabilities of DC on XXXXXXXXXX are as follows: Liabilities FMV ($) Taxes payable XXXXX Shareholder Loan XXXXX Total XXXXX PROPOSED TRANSACTIONS The Proposed Transactions will occur in the order presented unless otherwise indicated, with the exception of filing the applicable election forms, which will be filed within the applicable due dates, unless otherwise indicated, following the completion of the Proposed Transactions. ...

The aggregate FMV, immediately before the Distribution, of the Foreign Spinco Common Shares owned by Foreign Services will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Services is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror. ...

2002 Ruling 2002-0140733- XXXXXXXXXX- Sequential Butterfly Unedited CRA Tags 55(3)(b) 88(1) & (2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... The holders of the BF Subco Class A Special Shares shall be entitled to receive, as and when declared from time to time by the board of directors, dividends not exceeding an amount equal to XXXXXXXXXX % per annum calculated on the aggregate BF Subco Class A Redemption Amount. ... As a result, ChildA1 will own shares carrying more than XXXXXXXXXX % of the total votes attaching to all outstanding shares of ChildA1Co. ...

The aggregate FMV, immediately before the transfer of property by Canadian DC to Canadian TC described in Paragraph 120, of the common shares of the capital stock of New DC owned by Forco 23 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 23 is the participant, Canadian DC is the distributing corporation and New DC is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 117. ... The aggregate FMV, immediately before the transfer of property by New DC to New TC described in Paragraph 135, of the shares of New DC owned by Forco 14 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 14 is the participant, New DC is the distributing corporation and New Global Holdco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 135. ...

Foreign PubCo is widely held, and, to the best of Foreign PubCo's knowledge, at XXXXXXXXXX, the only shareholder owning more than XXXXXXXXXX% of the ordinary shares of Foreign PubCo is Shareholder A – XXXXXXXXXX%. 7. ... The aggregate FMV, immediately before the transfer of property by DC to TC described in Paragraph 92, of the common shares of Foreign SpinCo owned by ForCo 2 will be equal to or approximate the amount determined by the formula, on the assumption that ForCo 2 is the participant, DC is the distributing corporation and Foreign SpinCo is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 88. ...

Principal Issues: (i) Can we rule that a particular royalty, relating to XXXXXXXXXX in Canada, will constitute a "XXXXXXXXXX "? ... As outlined in more detail in Ruling 2, Y Co. acquired its working interest in the Project on XXXXXXXXXX pursuant to an arrangement whereby A Co. sold to Y Co. its XXXXXXXXXX% undivided working interest in the Project ("Working Interest 2") reserving a XXXXXXXXXX % net profit interest (the royalty so reserved being "Royalty 2"). ... The Purchase and Sale Agreement closed on XXXXXXXXXX with the base purchase price being adjusted and allocated as follows: New Trust Ordinary Units $ XXXXXXXXXX New Trust Series 1 Special Units XXXXXXXXXX New Trust Debt XXXXXXXXXX C Co. shares XXXXXXXXXX Option XXXXXXXXXX $XXXXXXXXXX Pursuant to the Purchase and Sale Agreement, there may be further adjustments to the purchase price in the XXXXXXXXXX day period following the closing of that agreement. 31. ...

This loan bears interest at a rate of Canadian prime + XXXXXXXXXX% and has been interest bearing since it was created in XXXXXXXXXX. ... The aggregate FMV, immediately before the Canadian DC Transfer, of the Foreign SpincoSub common shares owned by Forco 1 will be equal to or approximate the amount determined by the following formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Forco 1 is the participant, Canadian DC is the distributing corporation and Foreign SpincoSub is the acquiror. ...

Reasons: 1) See provisos in the ruling given. 2) See provisos in the ruling given. 3) It meets the required level of integration discussed in ITTN # 34. ...

The significant assets of DC include: (i) cash; (ii) investment assets in the form of three (3) XXXXXXXXXX properties (Property1, Property2 and Property3); and (iii) a XXXXXXXXXX per cent (XXXXXXXXXX %) equity interest (Common Shares) together with certain indebtedness in Opco which is a corporation engaged in the business of XXXXXXXXXX. ...