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The FMV of the marketable security portfolio held by DC is approximately $XXXXXXXXXX and of that, over XXXXXXXXXX % represents shares held in the capital stock of Investco A, Investco B, and Investco C. 2. ...

2006 Ruling 2006-0178401R3- 132.2 reorganization of a mutual fund trust Unedited CRA Tags 132.2 97(2) 85(1) 253.1 Principal Issues: Reorganization of an existing mutual fund trust, trust- on-corporation structure to a trust-on-partnership structure using rollovers available under s. 85, s.97 and 132.2; Additional issues encountered include deductibility of interest; debt forgiveness; acb of partnership interest & status of the mutual fund trust. ...

The fair market value, immediately before the Spin-off described in Paragraph 59, 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). ...

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

On XXXXXXXXXX, HLP and HOLDCO closed a debt private placement with a third party for $XXXXXXXXXX in senior secured long term debt at a fixed rate of interest of XXXXXXXXXX %. ...

The issued and outstanding shares of DC are held as follows: Shareholder Number & Class of Shares Transferee1 XXXXXXXXXX Class A Shares Transferee1 XXXXXXXXXX Class C Shares Transferee2 XXXXXXXXXX Class C Shares Transferee1 XXXXXXXXXX Common Shares Transferee2 XXXXXXXXXX Common Shares Transferee1 controls DC by virtue of its XXXXXXXXXX Class A Shares and XXXXXXXXXX Common Shares. ...

.; "Amalco" means the corporation resulting from the amalgamation of Newco3 and Holdco, as described in Paragraph 31; "Amalco Assets" means all of the assets beneficially owned by Amalco immediately following the transfer of the Holdco Partnership Interest XXXXXXXXXX to New LP described in Paragraph 34, XXXXXXXXXX; "Asset Transfer" means the transfer of the Amalco Assets by Amalco to the Trust described in Paragraph 36; "Asset Transfer Time" means the "transfer time" described in Paragraph 36; "Bank Debt" means Holdco's bank debt described in Paragraph 6; "Class A Shares" means the Class A preferred shares of Newco3 described in Paragraph 17(b) and, following the amalgamation described in Paragraph 31, the Class A preferred shares of Amalco; "Class A Redemption Amount" means an amount equal to $XXXXXXXXXX per Class A Share plus an amount equal to all declared and unpaid dividends on the share to the date of redemption or retraction multiplied by the number of Class A Shares outstanding immediately prior to the time of redemption or retraction; "Class A Subscription Proceeds" means the subscription proceeds of $XXXXXXXXXX per Class A Share as described in Paragraph 27; "Class B Shares" means the Class B preferred shares of Newco3 described in Paragraph 17(c) and, following the amalgamation described in Paragraph 31, the Class B preferred shares of Amalco; "Class B Redemption Amount" means an amount equal to the aggregate fair market value of the Holdco Shares and the Holdco Subordinated Debt at the moment when they are transferred to Newco3 as described in Paragraph 29 by the Trust in consideration for the issuance of XXXXXXXXXX Class B Shares plus all declared and unpaid dividends to the date of redemption or retraction; "Common Shares" means the common shares of Newco3 described in Paragraph 18 (a) and, following the amalgamation described in Paragraph 31, the common shares of Amalco; "Common Share Subscription Proceeds" means the aggregate subscription proceeds of $XXXXXXXXXX for the XXXXXXXXXX Common Shares issued to the Trust, as described in Paragraph 20; "cost amount" has the meaning assigned by subsection 248(1); "Court" means the XXXXXXXXXX; "CRA" means the Canada Revenue Agency; "Declaration of Trust" means the declaration of trust dated XXXXXXXXXX pursuant to which the Trust was formed as amended, XXXXXXXXXX; XXXXXXXXXX "Effective Date" means the date shown on the certificate of arrangement evidencing completion of the arrangement under section 192 of the Second Act; "Effective Time" means the first moment in time on the Effective Date; "Exchange XXXXXXXXXX " means the XXXXXXXXXX Stock Exchange; XXXXXXXXXX "fiscal period" has the meaning assigned by subsection 249.1(1); "Holdco" means XXXXXXXXXX., a corporation subject to the Second Act. ...

The authorized and issued capital of XXXXXXXXXX was as follows: Authorized Shares Issued Shares Common unlimited XXXXXXXXXX The shares of XXXXXXXXXX are owned as follows: Shareholder Number of shares held % XXXXXXXXXX 11. ...

XXXXXXXXXX deals with the XXXXXXXXXX tax services office and files its corporate tax returns with the XXXXXXXXXX Taxation Centre. 8.XXXXXXXXXX has acquired the ownership of XXXXXXXXXX, as emphyteutic lessor from XXXXXXXXXX 9.The authorized share capital of XXXXXXXXXX consists of an unlimited number of voting participating common shares without par value and an unlimited number of non-cumulative, non-voting, redeemable and retractable preferred shares without par value with a flexible non-cumulative dividend rate not to exceed XXXXXXXXXX% per annum. 10.The issued share capital of XXXXXXXXXX consists of XXXXXXXXXX common shares and XXXXXXXXXX preferred shares owned as follows: Class & Adjusted Paid-up Shareholder Number Cost Base Capital XXXXXXXXXX 11.The common shares of XXXXXXXXXX were issued upon incorporation in exchange for cash consideration of $XXXXXXXXXX per share. ...

Because the financial affairs of XXXXXXXXXX are inextricably linked with each other through the pooling of cash flows, intercorporate loans & guarantees and incurring and reallocating of common costs, this group of companies, along with any other directly or indirectly owned subsidiaries, are herein collectively referred to as "XXXXXXXXXX" for the purposes of this letter, except where otherwise noted. 5. ...