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Proposed transactions under Plan of Arrangement After purchasing for cancellation any common shares of dissenting shareholders, the Taxpayer will transfer the third property to a newly-incorporated subsidiary (“Newco”) in consideration for common shares of Newco (the “Newco Distribution Shares”) equaling in number the number of outstanding common shares of the Taxpayer. ...

Finance Trust will transfer all of the US Holdco Notes held by it (being most of its property) to the REIT for no consideration (the “Disposition”). ...

For the purposes of Part XIII and s. 116, any amount paid or credited by a payer to the sub-custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

Newco will acquire the shares of Holdco for cash consideration funded as described in above, for a note and for Class B non-voting redeemable retractable preferred shares of Holdco (whose paid-up capital is limited in accordance with s. 84.1(1)(a)), with a s. 85(1) election being made. ...

In connection with unwinding the loss consolidation arrangement, Newco will redeem the Newco Preferred Shares held by NewLossco in consideration for a non-interest bearing promissory note (the “Newco Note”), with NewLossco repaying the IB Loan by assigning the Newco Note to Lossco, and with Newco and Lossco will agree to set off the amount due under the NIB Loan against the amount due under the Newco Note. ...

UScorp2 will sell all of the shares of USco1 to Foreignco2 (so as to avoid split ownership of Amalco) for fair market value consideration. ...

An interest-bearing loan is owing by Bco to Cco (the "Cco-Bco Loan") Proposed transactions Bco will transfer to Newco all its common shares of Cco on a s. 85(1) rollover basis in consideration for Newco issuing common shares and a demand non-interest bearing promissory note (the "Bco-Newco Note"), which is convertible after a specified period at the holder’s option into Newco common shares with an FMV equaling that of the note. ...

Post-Arrangement Transactions Parent Amalco engaged in various transactions to increase the PUC of its shares of a Canadian subsidiary (“Corporation”) to their adjusted cost base or ACB including transferring a Canadian royalty interest (providing a net smelter return) and shares of four subsidiaries (having, depending on the subsidiary, an FMV higher or lower than their PUC, before giving effect to full s. 111(4)(e) step-ups of the appreciated shares) in consideration for preferred shares with a PUC equal to the s. 85(1) elected amount. ...

Canco will sell all of its shares of CFA to Forco 1 for cash consideration equal to their fair market value and elect under s. 93(1) to the extent of any capital gain. ...

Permitted exchanges/Three-Party Share Exchange Foreign Sub 1 will concurrently make the following transfers of its shares of DC (which will not be taxable Canadian property): (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)). ... DC transfers assets to TC including A Co and E Co (the Foreign Subsidiaries of CFAs) in consideration for the assumption of liabilities and the issuance by TC of preferred shares, so that the proportion of the net business assets received by TC approximates the ratio of the FMV of the DC Special Shares to the FMV of all the issued and outstanding DC shares. ...