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X and their FMV, for example, without taking into consideration, amongst other things, the CRA's valuation principles, practices and policies in Information Circular 89-3, while a prudent and conscientious person exercising due diligence would have done it. ...

None of the issued shares referred to herein (including the shares to be issued as described in the Proposed Transactions) are or will 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)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 21. ...

The corporations the shares of which will be transferred are foreign affiliates of Opco, the purchaser will be a foreign affiliate of Opco immediately after the transfer, the consideration paid will include shares of the capital stock of the acquiring affiliate. ...

In the case of a non-resident of Canada, subsection 70(5) of the Act applies in respect of each property owned by that non-resident immediately before death that is taxable Canadian property as defined in subsection 248(1) of the Act, subject to any tax treaty considerations. ...

The 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 agreement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act 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. 24. ...

Newco issued a note payable to the Partnership as the only consideration for the purchase of the membership interest. ...

It should be noted that any additional facts you may be aware of, in respect of Canco's activities in XXXXXXXXXX, should be taken into consideration when you are ultimately determining a reasonable allocation. ...

Holdco will transfer all of its shares in Canco and US Parent, respectively, to the Partnership at their fair market value in consideration for additional partnership units. ...

The Trustees will set the amounts to be paid by Employees to the Trust Fund as consideration for their ongoing participation in the Plan. ...

However, since by holding the donated Units, the Charity takes on the risk of changing prices, you advise that no Charity is likely to assume the price risk and will sell the Units to the Liquidity Provider. 19) As consideration for having arranged the series of transactions, the Charities will pay a fee to the Corporation equal to XXXXXXXXXX% of the gross selling price of any Units sold to the Liquidity Provider. 20) You advise that all purchases, transfers and dispositions of the Units will comply with all applicable securities laws. ...