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DC has estimated its tax accounts as of XXXXXXXXXX as follows: (a) RDTOH – $XXXXXXXXXX (b) GRIP- $XXXXXXXXXX (c) CDA- $XXXXXXXXXX (d) pre-1972 CSOH- $XXXXXXXXXX Specifically, DC will not have any CDA or pre-1972 CSOH balance immediately before the Proposed Transactions. ...

XXXXXXXXXX; "US Treaty" means the Canada – United States Tax Convention (1980), as amended by the Protocols thereto. ...

In the present case, the phrase "dependent … on …sales of goods" could thus, as argued by counsel for the respondent, include payments which are dependent on the sales of goods by third parties, like the sales by the manufacturers to Hasbro. ...

Immediately before the transfer of the Newco Common Shares by DC to TC as described in Paragraph 80, the aggregate FMV of the Foreign Spinco Parent common shares owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, DC is the distributing corporation, Foreign Spinco Parent is the acquiror and the distribution is the transfer of Newco Common Shares described in Paragraph 80, (A x B/C) + D As found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 72. ...

Prior to entering into the Proposed Transactions, the issued and outstanding shares of the capital stock of DC, which represent Capital Property to its shareholders, will be held as follows: Shareholder # Common Shares PUC ACB FMV SCo XXXXX $XXXXX $XXXXX $XXXXX WCo XXXXX $XXXXX $XXXXX $XXXXX 4. ...

DC’s assets consist of the following: (a) cash; (b) income taxes receivable; (c) marketable securities; (d) XXXXXXXXXX percent (XXXXXXXXXX %) of the issued and outstanding shares of the capital stock of XXXXXXXXXX, a CCPC; (e) furniture having a FMV of $XXXXXXXXXX; and (f) XXXXXXXXXX 3. ...

In XXXXXXXXXX, ECo L.P. collected from its shippers $ XXXXXXXXXX and contributed an equivalent amount to the ECo Reclamation Trust. 40. ...

Since the amount of total gifts for the taxation year of an individual in the year the individual dies is not limited to XXXXXXXXXX % of the individual's income for the year, Individual A's estate could have donated property to a qualified donee to fully offset any capital gains tax liability otherwise payable in respect of the year of Individual A's death. 45. ...

During XXXXXXXXXX lifetime, XXXXXXXXXX will own XXXXXXXXXX common shares of Trustco, which will represent XXXXXXXXXX % of the issued shares of Trustco. 28. ...

Immediately after this share exchange, the FMV of each Participant's share of the capital stock of Spinco will approximate 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). ...