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On or before the date of the Continuation, the Fund will distribute an amount to unitholders that would be sufficient to result in the Fund not being subject to tax if it earned no further income and realized no further capital gains or losses in its taxation year in which the Continuation occurs (taking into account amounts already distributed in 2014, and capital gains refunds that may arise for redemptions that occur in connection with the Continuation). ...

DeeThree/Boulder/Granite Oil-- summary under Butterfly spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Butterfly spin-offs Butterfly spin-off by DeeThree Exploration of Boulder Energy Overview Under an Alberta Plan of Arrangement, DeeThree will transfer its Brazeau Belly River assets (the "Spin-Off Assets") on a rollover basis to Boulder in connection with a butterfly spin-off of Boulder to its shareholders. ...

The Corporation will not be obligated to participate in any Pre-Acquisition Reorganization unless the Corporation determines in good faith that such Pre-Acquisition Reorganization: can be completed prior to the Effective Date, and can be reversed or unwound in the event the Arrangement does not become effective without adversely affecting the Corporation, any of its Subsidiaries, the Corporation Securityholders or holders of Debentures; is not prejudicial to the Corporation, any of its Subsidiaries, the Corporation Securityholders or holders of Debentures; and does not require the Corporation or its Subsidiaries to take any action that could reasonably be expected to result in Taxes being imposed on, or any adverse Tax or other consequences to, any Corporation Securityholders or holders of Debentures incrementally greater than the Taxes or other consequences to such party in connection with the completion of the Arrangement in the absence of such action being taken. ...

The Corporation will not be obligated to participate in any Pre-Acquisition Reorganization unless the Corporation determines in good faith that such Pre-Acquisition Reorganization: can be completed prior to the Effective Date, and can be reversed or unwound in the event the Arrangement does not become effective without adversely affecting the Corporation, any of its Subsidiaries, the Corporation Securityholders or holders of Debentures; is not prejudicial to the Corporation, any of its Subsidiaries, the Corporation Securityholders or holders of Debentures; and does not require the Corporation or its Subsidiaries to take any action that could reasonably be expected to result in Taxes being imposed on, or any adverse Tax or other consequences to, any Corporation Securityholders or holders of Debentures incrementally greater than the Taxes or other consequences to such party in connection with the completion of the Arrangement in the absence of such action being taken. ...

New Endo will be re-registered as a public limited company in connection with the Arrangement. ... Irish tax consequences Shareholders who are not resident in Ireland and do not hod their shares in connection with an Irish trade will not be subject to Irish tax on chargeable gains. ...

CAP REIT and ResREIT intend to jointly elect under s. 132.2 In the event that less than $175M in cash in paid out in connection with the Offer, CAP REIT intends to use the balance to make a special post-Merger distribution to all CAP REIT unitholders (including former ResREIT unitholders) or apply it to a special issuer bid. ...

Proposed transactions In connection with the implementation of the Transaction: SUSO 3 will acquire the shares of the GP of its immediate Ontario subsidiary LP from SLAM. ...

No fractional Hudbay Shares, or following the Redemption, Hudbay Warrants, will be issued or delivered in connection with the Amalgamation or the Redemption.. ...

Due Bill trading procedures will be used in connection with the distribution of the Newco shares. ...