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Public Transaction Summary

Ipsen/Clementia -- summary under Canadian Buyco

CVRs may not be transferred other than (i) upon the death of a holder, by will or intestacy; (ii) pursuant to a court order; (iii) by operation of law (including by consolidation or merger) or without consideration in connection with the dissolution, liquidation or termination of any corporation, limited liability company, partnership or other entity; (iv) in the case of CVRs held through book-entry or other similar nominee form, from a nominee to the beneficial owner. ...
Public Transaction Summary

European Commercial REIT/CAPREIT -- summary under Asset Purchases

In addition, in connection with the Acquisition, Unitholders and holders of Class B LP Units will receive a one-time special distribution of $0.50 per unit funded by CAPREIT. ...
Public Transaction Summary

Bitcoin Fund -- summary under Cryptocurrency Funds

.”); and Class B Units, which will be issued to 3iQ Bitcoin Trust and distributed to its unitholders in connection with the merger of 3iQ Bitcoin Trust into the Fund (the “Merger”) and which will be reclassified, on the closing of the Offering. into that number of Class A Units based on the Net Asset Value per Class B Unit divided by the Net Asset Value per Class A Unit. ...
Folio Summary

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subparagraph (a)(v)

(The payment also is not a contribution.) 3.13 However, in connection with a promotional contest, a cash prize paid directly to the winner’s plan would be covered by the (a)(v) exception, but would be a contribution "because such cash prizes are not considered a return on investment. ...
Folio Summary

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subparagraph (b)(iii)

That is, the advantage tax will nonetheless apply in respect of any future increases in the total FMV of the property held in connection with the plan that are reasonably attributable, directly or indirectly, to the swap transaction. ...
Folio Summary

S4-F11-C1 - Meaning of Farming and Farming Business -- summary under Paragraph 4(1)(a)

Whether these are part of the same business depends upon the connection, interlacing, dependence, and unity, of the operations. ...
Folio Summary

S1-F3-C2 - Principal Residence -- summary under Paragraph 45(1)(c)

In these and similar cases, the taxpayer reports the income and may claim the expenses pertaining to the altered portion of the property (that is, a reasonable portion of the expenses relating to the whole property) as well as CCA on such altered portion of the property. 2.59 It is the CRA’s practice not to apply the deemed disposition rule, but rather to consider that the entire property retains its nature as a principal residence, where all of the following conditions are met: a) the income-producing use is ancillary to the main use of the property as a residence; b) there is no structural change to the property; and c) no CCA is claimed on the property. 2.60 These conditions can be met, for example, where a taxpayer carries on a business of caring for children in the home, rents one or more rooms in the home, or has an office or other work space in the home which is used in connection with business or employment. ...
Public Transaction Summary

Intergeo/Mercator -- summary under Reverse takeovers

It filed a preliminary long form base PREP prospectus in Canada on May 15, 2012 in connection with a proposed IPO, but withdrew the prospectus on April 12, 2013 due to market conditions. 114M Intergeo shares are outstanding. ...
Public Transaction Summary

Pozen/Tribute -- summary under Inversions

Parent A private limited company formed on May 12, 2015 under the laws of Ireland which has not conducted any material activities other than in connection with the proposed transactions. ...
Public Transaction Summary

Central GoldTrust -- summary under Closed-End To Open-Ended Funds

In addition, if any gain realized by GoldTrust in connection with a redemption of Units is allocated to a non-resident of Canada and the CRA were to assess GoldTrust on the basis that the gain is taxable as income rather than as a capital gain, GoldTrust could be liable to pay Canadian non-resident withholding tax on such allocation under Part XIII of the Tax Act. ...

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