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Public Transaction Summary

Minto -- summary under Domestic REITs

The REIT will issue Special Voting Units in connection with the issuance of the Class B Units, each of which will carry one vote per Special Voting Unit. ... In connection with the amendment and restatement of the Partnership limited partnership agreement), MPI will exchange its limited partner interest in the Partnership for Class A Units, Class B Units and Class C Units. Special Voting Units will be issued by the REIT to MPI in connection with the issuance of the Class B Units. ...
Public Transaction Summary

Maxar -- summary under New Non-Resident Holdco

Maxar-- summary under New Non-Resident Holdco Summary Under Tax Topics- Public Transactions- Other- Continuances/Migrations- New Non-Resident Holdco Maxar Canada shareholders exchanged all their shares for a new U.S. holding company Overview In connection with regulatory approval of its acquisition of DigitalGlobe, Maxar Technologies Ltd. ... Reasons for Domestication In connection with regulatory approval of its acquisition of DigitalGlobe, the U.S. ... Whether gain under s. 367 Code s. 367 applies to certain non-recognition transactions involving foreign corporations and has the effect of imposing income tax on certain U.S. persons in connection with transactions that would otherwise be tax-free. ...
Folio Summary

S4-F8-C1 - Business Investment Losses -- summary under Subparagraph 40(2)(g)(ii)

S4-F8-C1- Business Investment Losses-- summary under Subparagraph 40(2)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) connection between loan and income-producing purpose 1.46... ... The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor.... 1.48 For an example of a case where the taxpayer did not own shares directly in the debtor corporation but a sufficient connection was shown to exist for the exception described in ¶ 1.44(a) to apply, see Alessandro v The Queen, 2007 TCC 411 &d1=&d2=&su=0"> 2007 TCC 411; 2007 DTC 1373 (TCC). For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592 &d1=&d2=&su=0"> 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163 "> 2005 FCA 163, 2005 DTC 5281). ...
Public Transaction Summary

Yamana/Extorre -- summary under Shares for Shares and Cash

A break fee of $15 million is payable in connection with the acceptance of a superior proposal or if the Extorre ceases to support the transaction. ...
Public Transaction Summary

Jackpotjoy/Intertain -- summary under New Non-Resident Holdco

Jackpotjoy/Intertain-- summary under New Non-Resident Holdco Summary Under Tax Topics- Public Transactions- Other- Continuances/Migrations- New Non-Resident Holdco Use by Intertain of an exchangeable share structure in connection with interposing a new public U.K. holding Overview Intertain, which is an OBCA holding company listed on the TSX, holds most of its assets in non-resident subsidiaries and generates substantially all of its (on-line gaming) revenues in Europe through such subsidiaries. ...
Public Transaction Summary

Slate Retail/ SUSO 2/GAR -- summary under REIT Mergers

" "GAR B also will be authorized to issue class A limited partnership units, which generally will be issued to the REIT in connection with a redemption of GAR B Exchangeable Units. ... Proposed transactions In connection with the implementation of the Combination Transaction: The SUSO 1 declaration of trust will be amended to make the SUSO 1 class I units convertible into SUSO 1 class U units (a.k.a., Class U Units) and to rename SUSO 1 as Slate Retail REIT (the "REIT"). ...
Public Transaction Summary

Jackpotjoy/Intertain -- summary under Exchangeable Share Acquisitions

Jackpotjoy/Intertain-- summary under Exchangeable Share Acquisitions Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Exchangeable Share Acquisitions Use by Intertain of an exchangeable share structure in connection with interposing a new public U.K. holding Overview Intertain, which is an OBCA holding company listed on the TSX, holds most of its assets in non-resident subsidiaries and generates substantially all of its (on-line gaming) revenues in Europe through such subsidiaries. ... The main purpose of the Capital Reduction is to: (a) create distributable reserves on the balance sheet of Jackpotjoy which will provide Jackpotjoy with flexibility to pay dividends in the future if appropriate and (b) to cancel the shares of Jackpotjoy issued in connection with its incorporation. ... U.K. tax consequences A disposal or deemed disposal of Jackpotjoy Shares by a holder who is not resident in the UK and is not is carrying on a trade in the UK through a branch or agency (or permanent establishment in the case of a corporate holder) in connection with which the Jackpotjoy Shares are used, held or acquired, will not generally be subject to UK taxation of capital gains unless the holder is an individual who has ceased to be resident for tax purposes in the UK for the purposes of double taxation arrangements ("treaty non-resident") for a period of less than five tax years of assessment and who disposes of all or part of his Jackpotjoy Shares during that period. ...
Public Transaction Summary

GFL -- summary under Prepaid Share Purchase

Applicable Market Value of Subordinate Voting Shares Settlement Rate Value of Shares Delivered Less than the reference price 2.6316 subordinate voting shares Less than US$50.00 Less than or equal to the threshold appreciation price but greater than or equal to the reference price A number of subordinate voting shares equal to US$50.00 divided by the applicable market value US$50.00 Greater than the threshold appreciation price 2.1930 subordinate voting shares Greater than US$50.00 Early settlement Preliminary steps In connection with, and prior to, the closing of the Concurrent Offering, Holdings will amalgamate with GFL, a wholly owned subsidiary of Holdings, and continue as GFL Environmental Inc. In connection with such amalgamation: Certain of the shareholders will subscribe for additional shares of Holdings at the offering price in the Concurrent Offering (using, in part, the proceeds of a margin loan made by dealer affiliates), the proceeds of which, together with a loan from the Dovigi Group for $29 million, payable in equal semi-annual instalments over five years and bearing market interest, will be used to repay in full the PIK Notes of $1B owing by Holdings; the shares being sold by the selling shareholder in the Concurrent Offering will be acquired as a result of such subscriptions; the share capital will be amended such that it will be composed of an unlimited number of multiple voting shares, an unlimited number of subordinate voting shares and an unlimited number of preferred shares, issuable in series; in connection with his resignation as an officer of GFL, Ven Poole will receive a separation payment of 73,947 subordinate voting shares issued at the initial public offering price in the amount of approximately US$1.4 million; the outstanding options will vest and convert into an aggregate of 3,202,956 subordinate voting shares; and all of the issued and outstanding shares of Holdings will be exchanged for subordinate voting shares and multiple voting shares based on an exchange ratio of 20.363259-for-one, other than the Class F shares of Holdings which will be exchanged for multiple voting shares, based on an exchange ratio of 26.343032-for-one. ...
Public Transaction Summary

Anderson/Freehold -- summary under Taxable spin-offs

In this connection Anderson and New Anderson will jointly elect under ITA s. 85(1) with an agreed amount as designated by New Anderson subject to Anderson comments, and will also jointly elect to have ITA s. 66.7(7)(e) apply, and the stated capital of the New Anderson common shares so issued will be equal to the s. 85(2.1) limit. ...
Public Transaction Summary

First Quantum/Inmet -- summary under Unsolicited Bids (corporate)

"The Offeror currently intends (x) that the consideration offered per Inmet Share under any Subsequent Acquisition Transaction proposed by it would be equal in value to and in the same form as the consideration paid to Shareholders under the Offer, (y) that such Subsequent Acquisition Transaction will be completed no later than 120 days after the Expiry Date and (z) to cause any Inmet Shares acquired under the Offer to be voted in favour of any such transaction and, where permitted by MI 61-101 to be counted as part of any Minority Approval required in connection with any such transaction. ...

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