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Immediately following the interest payment in 8, and in connection with the unwinding of the loss consolidation arrangement Newco will redeem the Newco Preferred Shares held by A Co in consideration for its issuance of a non-interest bearing promissory note (the "Newco Note"), then; A Co will repay Loan 2 by assigning the Newco Note to Lossco, then; Loan 3 and the Newco Note will be repaid by mutual set-off. ...

Permitted exchanges/Three-Party Share Exchange Foreign Sub 1 will concurrently make the following transfers of its shares of DC: (i) transfer all the DC Special Shares to TC, a newly-incorporated private corporation subsidiary of Foreign Sub 1 (para. 126(a)) in consideration for the issue of common shares of TC; and (ii) transfer all the DC New Common Shares to Foreign Sub 15, a newly-incorporated LLC subsidiary of Foreign Spinco 1 which, in turn will be a non-Canadian subsidiary of Foreign Sub 1 (para. 126(b)). ...

B and there are residual assets) for no consideration. They will make no direction regarding who is entitled to receive the benefit from disclaiming their interest. ...

FA2 will transfer all of its shares of FA5 to New FA3 in consideration for shares of New FA3. ...

Proposed transactions Bco will purchase Aco’s interest in Property 1 and Property 2 (being mining claims) in consideration for the reduction of the intercompany debt owing by Aco to Bco, with Aco including the proceeds of disposition in element F of the definition of “cumulative Canadian development expense.” ...

Proposed transactions Bco will purchase Aco’s interest in Property 1 and Property 2 (being mining claims) in consideration for the reduction of the intercompany debt owing by Aco to Bco, with Aco including the proceeds of disposition in element F of the definition of “cumulative Canadian development expense.” ...

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Canadian Sub-custodian in respect of the property held by the Subfund on behalf of the Pension Fund, including purchase consideration for such property, will be considered an amount paid or credited to the Pension Fund in proportion to its participation in the assets and income of the particular Subfund. ...

Proposed transactions Although all the Fund 1 and Fund 2 properties will continue to be legally and beneficially owned by the Taxpayer, a combination of the two Funds will be effected by the Taxpayer changing the allocation of properties for accounting and administrative purposes, so that all of the properties in Fund 1 will be allocated to Fund 2, with no consideration being paid. ...

On the butterfly distribution, DC transfers Newco to TCo in consideration for preferred shares and the assumption of liabilities, following which there is a cross-cancellation of the shareholdings between DC and TC, so that TC becomes an indirect wholly-owned subsidiary of Foreign Spinco. ...

Following the replacement of those notes and some of the newer debt with amended notes, and the transfer to the unitholders of units of a new fixed investment trust with nominal assets (the “F17 Trust”) in consideration for the nominal cash received by them for the transfer of their units of Finance Trust to the REIT (whose ACB will have been reduced under s. 107.4(3)(l)), the amended notes will be transferred by the REIT under s. 107.4 to the F17 Trust. ...