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As consideration therefor, the Estate will receive XXXXXXXXXX additional Class A shares of Newco and a non-interest bearing demand promissory note (the “Promissory Note”) having a principal amount equal to the ACB of the Remaining Shares, less $XXXXXXXXXX. ... This purpose was accomplished in the particular manner described in Paragraphs 9.1 and 11 for practical rather than tax considerations. 32. ...

3) During which period shall the Minister reassess a taxpayer in order to take into consideration a reduction of an amount otherwise required to be included in computing the deceased's income, as permitted by subsection 146.3(6.2)? 4) When does an amount need to be paid by or on behalf of a taxpayer to a carrier as consideration for a RRIF in order to be deductible under paragraph 60(l)? ...

En pareil cas, s'il est raisonnable de conclure que l'existence distincte des sociétés est motivée essentiellement par des considérations fiscales, les sociétés seront réputées associées l'une à l'autre. ... Une analyse des opérations et des états financiers des deux sociétés révélait clairement la prise en compte d'un certain nombre de considérations fiscales par M. ...

Position: (1) no (2) no (3) no Reasons: (1) The changes are not considered material or significant to result in a resettlement of the trust and it is submitted that there will be no resettlement as a matter of provincial law. (2) No cash consideration or other proceeds of disposition will be received by the unitholders in respect of the diminishment of their rights as a consequence of the amendments. ... Unitholders will not receive any financial compensation or proceeds of any kind whatever, as consideration for the issuance of the XXXXXXXXXX Preferred Units; nor will Units be redeemed or cancelled as a result of the issuance of the XXXXXXXXXX Preferred Units. 24. ...

No other consideration will be received by any holder of the Common Shares. ... Comments Nothing in this ruling letter should be construed as implying that the Canada Revenue Agency has agreed to, reviewed or has made any determination in respect of: (a) the FMV or ACB of any property or the PUC of any shares referred to herein; (b) foreign law or foreign tax considerations; or (c) any tax consequences relating to the facts and Proposed Transactions described herein other than those specifically described in the rulings given above. ...

Immediately following the payment of interest to Lossco, described in Paragraph 22, the following transactions will occur to unwind the loss consolidation arrangement: (a) Newco will redeem the Newco Preferred Shares held by A Co in consideration for a non-interest bearing promissory note issued by Newco (the "Newco Note"). ... The Newco Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be: (a) the subject of any undertaking that is a guarantee arrangement; (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); (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph112(2.4)(b)(i),or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 39. ...

Prior to XXXXXXXXXX, USSub sold the USSub Note to USco for cash consideration equal to the fair market value of the USSub Note. 19. ... On or before XXXXXXXXXX, USSub will sell the USSub Debentures to USco, for cash consideration equal to the fair market value of the USSub Debentures. 21. ...

On or around XXXXXXXXXX, SubCo proposes to transfer the Expansion Wells and the Leases forming part of the Expansion Lands (the "Property") to Partnership 2 as follows: (a) SubCo will transfer the Property to Partnership 1 in consideration for an additional partnership interest in Partnership 1. ... (b) Partnership 1 will transfer the Property to Partnership 2 in consideration for an additional partnership interest in Partnership 2. ...

(c) The Net Profits of the Partnership are divided amongst the Partners giving consideration to the billings and collections attributed to the Partners, the overhead attributed to the Partners, the business relationships between the Partners and clients, the generation of work by the Partners for associates and employed XXXXXXXXXX and the contribution of the Partners to the operation of the Partnership. ... Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 25. ...

B Co and C Co will enter into an agreement whereby B Co will sell its common shares in E Co to C Co in consideration for common shares having a fair market value equal to the fair market value of the E Co common shares. ... The Newco Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be: (a) the subject of a dividend rental agreement; (b) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (c) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). ...