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The Preferred Shares will not, at any relevant time, be: a) the subject of any undertaking that is a guarantee agreement; b) the subject of a dividend rental arrangement; c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d) issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 45. ...

The CRA will take into consideration how the taxpayer reports under the new accounting standards as part of our review of the taxpayer's determination of profit under GAAP. ...

The CRA will take into consideration how the taxpayer reports under the new accounting standards as part of our review of the taxpayer's determination of profit under GAAP.... whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ...

The Lossco Class B Preferred Shares will not at any time during the implementation of the Proposed Transactions be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 34. ...

At no time during the implementation of the Proposed Transactions described in this letter will the Preferred Shares be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”, including any guarantee, covenant, or agreement to purchase the Preferred Shares and including the lending of funds to or the placing of amounts on deposit with, or on behalf of, Profitco 1 or Profitco 2 or a specified person in relation to either of the foregoing (as contemplated by subsection 112(2.2)) given to ensure that (i) any loss that Profitco 1 or Profitco 2 or a specified person in relation thereto may sustain by reason of the ownership, holding or disposition of the Preferred Shares or any other property is limited in any respect, or (ii) Profitco 1 or Profitco 2 or a specified person in relation to either of the foregoing will derive earnings by reason of the ownership, holding or disposition of the Preferred Shares or any other property; (b) the subject of a dividend rental arrangement (nor will any of the dividends paid on the Preferred Shares in the course of the Proposed Transactions be received as part of a dividend rental arrangement); further, the Preferred Shares will not be the subject of a dividend rental arrangement pursuant to the amended definition of dividend rental arrangement in accordance with the Legislative Proposals to amend the Act issued on July 31, 2015, and including as described in proposed paragraphs (c) and (d) of that definition; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration (nor will Profitco 1 or Profitco 2 receive any other property, directly or indirectly, from an investor or any property substituted therefor) that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that would be related to Lossco (if the Act were read without reference to paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 20. ...

(v) Pursuant to a written agreement and in consideration for a fair market value fee, the Partnership will supply to the ProCorp certain supplies, personnel and equipment that are required to provide Professional Services XXXXXXXXXX. ...

The Lossco Preferred Shares will not be, at any time during the implementation of the Proposed Transactions described herein: a) the subject of any undertaking that is a guarantee agreement; b) the subject of a dividend rental arrangement; c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d) issued for consideration that is or includes: I. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or II. any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 32. ...

The former shareholders of Foreign Co 1 received no consideration on the amalgamation; whereas the former shareholders of Foreign Co 2 received shares of Foreign Co 1 on the amalgamation. ...

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 26. ...

Based on the context of subparagraph 95(2)(a)(ii) and the implications of the possible interpretations, it is our view that the term "payable" with respect to debt obligations covered by subparagraph 95(2)(a)(ii) means amounts calculated on an accrual basis for the taxation year under consideration. ...