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Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39 -- summary under Regulation 805

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 Factual distinction between business and property income for corporation (p. 32:4) In the case of a corporation whose sole activity is the ownership of such property, there is a presumption that a corporation is formed for the purpose of carrying on business; accordingly, where the corporation has only one activity or investment—regardless of its nature—the corporation may be held to be carrying on a business in respect of such single activity or investment. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39 -- summary under Paragraph (a)

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (a) Quebec taxation of income from specified immovable property [N[on-resident inter vivos trusts that own immovable property in Quebec and that earn rental income from that property (that is, passive rental income that does not constitute business income earned through an establishment in Quebec) are also subject to provincial tax in Quebec. ...

H. Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99. -- summary under Subsection 2601(1)

Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99.-- summary under Subsection 2601(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(1) Structuring so that decisions are made in a different jurisdiction (pp. 692-3) Once the identity of the person who has central management and control is ascertained, the residence of the trust can be resolved by identifying the place where J that person exercises the powers constituting central management and control. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39 -- summary under Subsection 216(1)

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Tax computation where s. 216(1) election (p. 32-6) Where a section 216 election is made, income is computed as it is (in the manner set out above) to determine taxable income for business property, with one exception: losses of other years may not be applied in determining the taxable income. ...

Jim Samuel, "Interaction of the Foreign Affiliate Surplus and Safe-Income Regimes: Selected Anomalies, Issues, and Planning Considerations", Canadian Tax Journal, (2018) 66:2, 269-307 -- summary under Paragraph 55(5)(d)

Jim Samuel, "Interaction of the Foreign Affiliate Surplus and Safe-Income Regimes: Selected Anomalies, Issues, and Planning Considerations", Canadian Tax Journal, (2018) 66:2, 269-307-- summary under Paragraph 55(5)(d) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(d) Increasing the tax-free surplus balance for s. 55(5)(d)(i) purposes through Reg. 5907(2.1) election (p. 294) [G]enerally, if a regulation 5907(2.1) election is made,…at a time when the accumulated depreciation for financial statement purposes is less than it is for tax purposes, the affiliate's earnings (and thus its exempt surplus pool, and ultimately its TFSB) will be increased by the difference between these amounts…. ...

Pan American/ MAG Silver -- summary under Shares for Shares and Nominal Cash, or Cash

Accordingly, with proration, those receiving Share Consideration would receive Cash Consideration of around US$4.56 per MAG share. ... Concurrently with the steps below and subject to proration, each MAG share for which the shareholders elected Cash Consideration will be deemed to be transferred to Pan American in consideration for the Cash Consideration. ... Canadian Tax Considerations The exchange of the MAG shares for Cash Consideration or Share Consideration will occur on a non-rollover basis, except to the extent that an election under subsection 85(1) of the Income Tax Act is made by an Eligible Holder where there is Share Consideration. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F - Meaning of Any consideration received by Donee -- translation

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee-- translation ...

Radian/Wheel -- summary under Canadian Buyco

Each Wheels Share (other of a Dissenting Shareholder) will be transferred to the Purchaser by the holder thereof in exchange for the Cash Consideration, Share Consideration or Combined Consideration elected or deemed to be elected by such former Shareholder, subject to proration of the Share Consideration elected by the Locked-up Shareholders (and any other Wheels Shareholders who did not make a valid election). Canadian tax considerations The exchange will occur on a taxable basis. U.S. tax considerations The disposition of Wheels Shares for consideration in the Arrangement will be a taxable transaction to U.S. ...

Ipsen/Clementia -- summary under Canadian Buyco

Overview of Consideration The Arrangement Agreement provides for the implementation of a CBCA Arrangement pursuant to which, among other things, the Shareholders will receive, for each Share held, US$25.00 in cash upfront (the "Cash Consideration") for an initial aggregate consideration of approximately US$1.04 billion, plus deferred payments on the achievement of a future regulatory milestone in the form of a contingent value right ("CVR"), and together with the Cash Consideration, the "Consideration") of US$6.00 per Share upon U.S. ... Concurrently with the preceding step, each outstanding Share shall be transferred by the holder thereof to the Purchaser in exchange for the Consideration per Share. ... Internal Revenue Code (as discussed below) and the balance, in general, as additional consideration for the disposition of the Shares. ...

Endo/Paladin -- summary under New NR Holdco (Inversion)

Arrangement Consideration The Arrangement Cash Consideration for a Paladin Share consists of the Arrangement Cash Consideration, the Arrangement Stock Consideration and the Arrangement Therapeutics Consideration. The Arrangement Cash Consideration is $1.16 in cash, subject to adjustment. ... In consideration for the above-noted consideration, CanCo 1 will issue 35M common shares to New Endo having full stated capital. ...

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