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Accordingly, the first three sentences in Paragraph 24 are changed to read as follows: Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting of XXXXXXXXXX DC New Common Share and XXXXXXXXXX DC Butterfly Share. ...

After careful consideration of the cash requirements of Pubco, Pubco determined that the cash remaining after the Distribution would be adequate to support any potential growth of Pubco. ...

The subject of “dividend rental arrangement” as defined by subsection 248(1) with respect to any of the shares issued for the purposes of completing the Proposed Transactions; c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 19. ...

Raisons: 1) Afin de déterminer s'il y a un avantage imposable pour les employés, il faut prendre en considération la raison pour laquelle l'employeur rembourse ces frais et à qui bénéficie le plus de cet arrangement. 2) Position exprimée au paragraphe 15 du bulletin d'interprétation IT-470R(Consolidé), au paragraphe 8 du bulletin d'interprétation IT-131R et dans le guide de l'employeur T4130. 2006-021029 XXXXXXXXXX Anne Dagenais Avocate,M. ...

X and their FMV, for example, without taking into consideration, amongst other things, the CRA's valuation principles, practices and policies in Information Circular 89-3, while a prudent and conscientious person exercising due diligence would have done it. ...

None of the issued shares referred to herein (including the shares to be issued as described in the Proposed Transactions) are or will be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (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); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 21. ...

The corporations the shares of which will be transferred are foreign affiliates of Opco, the purchaser will be a foreign affiliate of Opco immediately after the transfer, the consideration paid will include shares of the capital stock of the acquiring affiliate. ...

In the case of a non-resident of Canada, subsection 70(5) of the Act applies in respect of each property owned by that non-resident immediately before death that is taxable Canadian property as defined in subsection 248(1) of the Act, subject to any tax treaty considerations. ...

The Preferred Shares will not be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental agreement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)) of the Act; or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 24. ...

Newco issued a note payable to the Partnership as the only consideration for the purchase of the membership interest. ...