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UPREIT structure The REIT is considered an umbrella partnership real estate investment trust (an “UPREIT”) for U.S. federal income tax purposes. ... Under FIRPTA, such gains are considered effectively connected with a U.S. trade or business of the foreign shareholder and are taxed at the normal graduated rates applicable to U.S. ...

Upon distribution of Class A Preferred shares to Unitholders, Crombie will be considered to have disposed of such Class A Preferred shares for proceeds of disposition equal to the fair market value of such Class A Preferred shares. ... Consolidation of Units The consolidation of the Units in Steps 10 and 20 will not be considered to result in a disposition of Units. ...

The REIT, Investment LP1 and GAR B will elect to be corporations under the Code and they each will be considered to have a permanent establishment in the U.S. ...

US Holdco is expected to make the election under Code s. 1059(c)(4) to have its basis in the shares of Regional Energy considered to be their much higher fair market value, for purposes of determining whether dividends from Regional Energy during the first two years of US Holdco's indirect investment therein are an extraordinary dividend (otherwise potentially giving rise to a negative basis gain). ...

A U.S. holder who receives DREAM shares under the Arrangement should be considered to have received a taxable distribution, so that if Dundee is not treated as a PFIC, such U.S. holder generally will be required to include the fair market value of DREAM shares in income to the extent of Dundee's current or accumulated earnings and profits. ...

S. 97(2) exchange Holders of True North Partnerships Class B Units who exchange their Units for Redeemable Units of the applicable partnership and who jointly elect under s. 97(2) will be considered to have disposed of their units for an elected amount which complies with s. 97(2). ...

A Resident Shareholder that transfers New Common Shares under the Arrangement to the Purchaser for the Consideration including any portion of the Contingent Payment Received, will be considered to have disposed of such New Common Shares for proceeds of disposition equal to the amount of the aggregate Consideration, including any portion of the Contingent Payment Amount received. ...

A Shareholder who exchanges Common Shares for REIT Units pursuant to the Arrangement will be considered to have disposed of such Common Shares for proceeds of disposition equal to the fair market value at the Effective Time of such REIT Units acquired by the Shareholder. ...

BBP LP would be considered to be "Canadian resident partnership" and, therefore taxable as a SIFT partnerships, if its central management and control were in Canada. ...

To the extent that shares of the Corporation are purchased by the Corporation pursuant to a normal course issuer bid, the shareholders should be considered by s. 84(6)(b) to have realized a capital gain or a capital loss on the disposition of their shares and the Corporation should not be deemed to have paid a dividend to the shareholders. ...