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Agrium/PotashCorp -- summary under New Holdco

Similarly, assets held prior to the Arrangement Transactions, and required to to be disposed of by regulatory authorities, or used to satisfy obligations of either PotashCorp or Agrium in connection with the Arrangement Transactions, will not be treated as acquired in the Arrangement Transactions. ...

Newmarket/Kirkland Lake -- summary under Triangular Amalgamations

Pursuant to the Amalgamation: (i) each Kirkland Share (other than Kirkland Shares held by Newmarket) will be cancelled in exchange for the “Consideration” of 2.1053 Newmarket Shares; (ii) each Kirkland Share held by Newmarket and each Subco Share will be converted into one share of the amalgamated corporation (“Amalco”); (iii) as consideration for the issuance of the Consideration by Newmarket in connection with the Amalgamation, Amalco will issue to Newmarket one Amalco Share for each Newmarket Share issued pursuant to (i) above; and (iv) there will be added to the stated capital of the Newmarket Shares an amount equal to the paid-up capital of the Kirkland Shares described in (i). ...

Leagold/Brio Gold -- summary under Triangular Amalgamations

Consequences of Arrangement Brio Gold shareholders will receive an approximate 42% ownership interest in Leagold post-Arrangement (assuming that Goldcorp does not exercise the Goldcorp Anti-Dilution Right in connection with the Arrangement). ...

Sprott Physical Uranium -- summary under Metals Funds

It was created in connection with the acquisition of the common shares of Uranium Participation Corporation (“UPC”), an OBCA corporation, under an Arrangement (on the basis on ½ of a Trust unit for each UPC common shares), and to invest and hold substantially all of its assets in physical uranium. ...

Loblaw/GWL/Choice -- summary under Butterfly spin-offs

Due Bill Trading Due Bill trading may only be used in connection with a “push-out” of listed securities (i.e. where the certificates representing the originally listed securities to which the entitlement attaches will not be replaced with new certificates; rather, only the entitlement (e.g. the dividend, shares of a new company, etc.) will be “pushed-out” to shareholders). In the case of the Arrangement, this means that Due Bill trading will only be used in connection with the LCL Common Shares, as the certificates representing the LCL Common Shares will not be replaced with new certificates. ...

S2-F1-C2 - Retiring Allowances -- summary under Retiring Allowance

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...

S4-F8-C1 - Business Investment Losses -- summary under Subsection 39(9)

Therefore, in connection with the disposition of the debt, Mr. R’s 2015 tax return will also reflect an allowable capital loss in the amount of $60,000 ($120,000 x one-half). ...

S4-F14-C1 - Artists and Writers -- summary under Commodities, and commodities futures and derivatives

An artist would generally be considered to have made a gift of capital property when the property gifted is property that would not normally be produced and sold in connection with their business. ...

S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 56(1)(r)

S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 56(1)(r) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(r) The deduction [under s. 110(1)(g) by way of s. 56(1)(r)] applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student's training. ...

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph 146(4)(a)

This position does not apply to borrowing that arises in connection with a cashless exercise of warrants or a margin account. ...

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