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Immediately following the DC Transfers, the FMV of each type of property transferred to each of Son Newco and Daughter Newco will be equal to or approximate the proportion determined by the formula: A * B / C Where: A is the FMV, immediately before the DC Transfers, of all property of that type owned at that time by DC; B is the aggregate FMV, immediately before the DC Transfers, of all of the shares of the capital stock of DC, owned at that time by Sonco or Daughter Holdco, as the case may be; and C is the aggregate FMV, immediately before the DC Transfers, of all the issued and outstanding shares of the capital stock of DC. 49. ...

30 October 1992 Income Tax Severed Letter 2M0333A- Published Version of 1991 Canadian Tax Foundation Unedited CRA Tags 30 / Various / Divers Revenue Canada Round Table Table Ronde de Revenu Canada* Robert M. ...

Partnership B does not have material property other than shares of Holdco (approximately XXXXXXXXXX % of the issued and outstanding shares of Holdco), various inter-entity receivables owing by entities in the DC Group and an interest in XXXXXXXXXX. ... In addition to its partnership interests in Partnership B and Partnership C, Subco B owns a XXXXXXXXXX partnership interest (approximately XXXXXXXXXX %) in Partnership F. 30. ... The fair market value, immediately before the transfer of Distribution Property by DC to Spinco in Paragraph 90(m), of each Participant's Spinco Common Shares, will be equal to the amount determined by the formula: (A x B/C) + D in respect of such Participant, as set out in subparagraph (b)(iii) of the definition of permitted exchange. ...

Partnership B did not have material property other than shares of Holdco (approximately XXXXXXXXXX % of the issued and outstanding shares of Holdco), various inter-entity receivables owing by entities in the DC Group and an interest in XXXXXXXXXX. ... In addition to its partnership interests in Partnership B and Partnership C, before the winding-up of Subco B, Subco B owned a XXXXXXXXXX partnership interest (approximately XXXXXXXXXX %) in Partnership F. 30. ... The fair market value, immediately before the transfer of Distribution Property by DC to Spinco in Paragraph 90(m), of each Participant's Spinco Common Shares, will be equal to the amount determined by the formula: (A x B/C) + D in respect of such Participant, as set out in subparagraph (b)(iii) of the definition of permitted exchange. ...

Pubco subscribed for one Spinco common share for $ XXXXXXXXXX. PROPOSED TRANSACTIONS Internal Funding- Pubco, Canco 1, FA 3, FA 4 and FA 1 19. ...

Yours truly, XXXXXXXXXX Manager for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

". In my view, this provision is to be interpreted as it would be understood in the mining industry, for which Parliament included Canadian exploration expense as defined in s/p (iii.1) as a benefit to attract investment in resource production. ...

If Annual Individual Goals and Annual Corporate Goals are only partially attained, the Participant may be entitled to receive a pro-rata portion of the Performance Vesting RSUs, the number of which will be determined at the discretion of the CEO or the Chair of the Board, as the case may be. e) No Participant shall be entitled to any benefit in respect of RSUs granted under the Plan to the extent that such RSUs have not vested in favour of the Participant. f) Subject to subparagraph 8(o) below, any RSUs applicable to a particular Grant to which a Participant does not become entitled under the Time Vesting Criteria, the Annual Corporate Goals or the Annual Individual Goals shall be forfeited immediately upon such determination. g) Upon the vesting of RSUs under the Plan, Pubco will determine the amount that is payable to a Participant based on the following formula: (Vested RSUs x Average Market Price on the Entitlement Date)- Tax Withholding = funds payable to the Participant h) The amount payable to the Participant (based upon the formula in subparagraph (g) above) will be paid to the Participant in cash. i) Pubco will pay amounts owing under the Plan to the Participant each year in which a Participant's RSUs vest. ...

Payroll Services Company, for and on behalf of Company One, shall charge back to Company One's customers the total cost of labour above + XXXXXXXXXX% premium for employee management, unless otherwise agreed to in writing. ...

., at paragraph 17, summarized the findings of the Supreme Court in First Vancouver as follows: The collection of source deductions is at the heart of income tax collection; The tax debtor's bank is more familiar with the debtor's business and finances than the Minister; Source deductions have priority over other creditors with respect to the collection of unremitted taxes; The special priority granted to the deemed trust prevails over property given as security, regardless of whether the security interest arose before or after the deductions for income tax or employment insurance were made [.] ...