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Sub2 will transfer its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and a non-interest bearing promissory note (the “Sub1 Note”), jointly electing under s. 85(1). ...

Sub2 will transfer its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and a non-interest bearing promissory note (the “Sub1 Note”), jointly electing under s. 85(1). ...

Sub2 will transfer its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and a non-interest bearing promissory note (the “Sub1 Note”), jointly electing under s. 85(1). ...

Acquisition and wind-up of Lossco A number of years later, Taxpayer will purchase all of the Lossco shares for nominal consideration and wind-up and dissolve Lossco (which is not expected to have any assets). ...

Proposed transactions The estate will transfer its voting Class C and non-voting G preferred shares of Holdco on a s. 85(1) rollover basis to a newly-incorporated corporation (with no shareholders yet) in consideration for Class A and C shares of Newco. ...

Concurrently with 3, Trust1 will transfer its shares of Opco1 to Newco for Newco in consideration for Class C shares of Newco with full PUC, electing under s. 85(1) at the transferred shares’ stepped-up ACB. ...

Proposed transactions The Continuing Shareholders and key employees will transfer their Pubco Shares to newly-incorporated Newco under s. 85(1) in consideration for common shares (or common shares and notes, in the case of the key employees). ...

The estate will transfer to a newly-incorporated corporation (“Newco”) its Class E shares of Holdco in consideration for Class A voting participating shares of Newco, electing under s. 85(1) (no price-adjustment clause). ...

AE Trust will transfer its common shares of Aco and Bco on a s. 85(1) rollover basis to a corporation newly-incorporated by it (Newco) in consideration for two notes of Newco and preferred shares whose redemption value is nominal subject to the operation of a price adjustment clause. ...

Proposed transactions The Trust will transfer its ACo common shares to a resident corporation newly-formed by it (“Newco”) in consideration for notes and Newco preferred shares, electing under s. 85(1). ...