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The key terms of the Guaranty Agreement are as follows: (a) the Financial Guarantor will be entitled to a premium in consideration of its issuing the Financial Guaranty; (b) Finco will be required to reimburse the Financial Guarantor for any payments the Financial Guarantor may be required to make under the Financial Guaranty; (c) Finco and the XXXXXXXXXX Entities acknowledge that the Financial Guarantor will be fully subrogated to the rights of the Bondholders and the Bond Trustee to the extent of any payments made by the Financial Guarantor under the Financial Guaranty; Finco and each of the XXXXXXXXXX Entities agree to indemnify the Financial Guarantor and its officers, directors, shareholders and similar persons from and against all claims, costs and expenses arising out of the Guaranty Agreement, and to reimburse the Financial Guarantor for fees, costs and expenses incurred pursuant to the Guaranty Agreement. 20. ...

At no time during the implementation of the Proposed Transactions described in this letter will the Newco Preferred Shares, or the Holdco, Lossco A, Lossco B, Lossco C shares 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); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 35. ...

In consideration of the services to be performed by the Custodian under the Custodian Agreement, the Custodian shall be entitled to receive such fees out of the properties of the CCF as may be agreed between the Custodian and the Manager from time to time and set forth in Schedule XXXXXXXXXX of the Custodian Agreement, subject to the maximum annual fee as disclosed in the Prospectus. g. ...

As part of the winding-up process, the Newco 1 Indebtedness will be settled for consideration equal to the amount of the Newco 1 Indebtedness. 40. ...

2012 Ruling 2011-0410181R3- Variation of trust indenture CRA Tags 104(7.1) 122.1(1) 248(1) 108(2)(b) Principal Issues: Whether the variation of a trust indenture to create and issue a new class of preferred units of a mutual fund trust would result in (1) a disposition by the trust of its assets or in a resettlement of the trust, (2) a disposition by the existing unitholders of their units, (3) the application of 104(7.1), and (4) a negative impact with respect to the definition of "real estate investment trust" in subsection 122.1 Position: (1) no (2) no (3) no (4) no negative impact on whether the trust meets the definition of "REIT" Reasons: (1) The changes are not so extensive so as to result in a resettlement of the trust and it is submitted that there will be no resettlement as a matter of provincial law. (2) No cash consideration or other proceeds of disposition will be received by the unitholders in respect of the diminishment of their rights as a consequence of the amendments. ...

Without restricting the generality of the preceding statement, it should be noted that nothing in this letter should be interpreted as confirming, either expressly or implicitly, that the CRA has agreed to, reviewed or has made any determination in respect of the following: 1. dividends on any share of any corporation mentioned above, except to the extent addressed by rulings I and J, 2. the application of subsection 20(12), 3. any foreign tax credit claim in accordance with section 126, 4. whether the facts, completed transactions and proposed transactions described herein are, or would be undertaken for fair market value considerations, 5. the reasonability of all amounts paid or received, 6. any other tax consequences relating to the facts, completed transactions, proposed transactions or subsequent to the proposed transactions, whether described in this letter or not, other than those specifically described in the rulings given above, 7. the application of subsection 245(2) in respect of any provision subject to the caveat. ...

Toutefois, il faudrait prendre en considération qu'elle a déjà été imposée sur les revenus qui lui ont été attribués par Fiducie. ...

Dans la mesure où, dans le calcul de la provision, ces obligations ont été prises en considération, le montant de la provision devrait être réduit. 13 Canderel Ltd. v. ...

Dans la mesure où, dans le calcul de la provision, ces obligations ont été prises en considération, le montant de la provision devrait être réduit. 12 Canderel Ltd. v. ...

The calculation of the taxable benefit should take in consideration the employee economic enrichment in comparison of his pre-assignment housing costs. ...