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Under the CRA administrative practices, a dissenting shareholder should be considered to have disposed of its Delavaco shares for proceeds of disposition equal to the amount paid by Amalco (excluding any interest). i.e., no deemed dividend treatment. ...

Resident dissenting shareholders will be considered to have received proceeds of disposition equal to the cash compensation received by them (other than any interest award, which would be ordinary income). ...

Potential debt character of Exchangeable Securities Under IFRS, it was possible that, without certain amendments to the terms thereof including the exchange provisions, the various Exchangeable Securities of Calloway LP, Calloway LP II and Calloway LP III (i.e. the various series of Class B and Class D limited partnership units of Calloway LP, Calloway LP II and Calloway LP III that are convertible or exchangeable directly for Units without the payment of additional consideration therefor) would be considered debt instead of equity (as they are currently classified since they are intended to be the economic equivalent of Units). ...

S. 86 will apply to such exchange so that a holder of Yoho common shares will be considered to have disposed of its shares for the greater of their adjusted cost base and the fair market value of the Storm shares received on the exchange. ...

A resident holder who receives Suncor Shares in exchange for COS Shares on the Amalgamation will not realize any capital gain or capital loss as a result of the exchange, and will be considered to have disposed of its COS Shares for proceeds of disposition equal to their aggregate adjusted cost base. ...

It will rely on not holding non-portfolio property; and on US co-investors in the wind projects not being considered to be investors in it for purposes of the US inversion rules. ... None of the Vendors will hold an interest in it, and it will not initially acquire substantially all the interests in the project LLCs (although s. 7874 could apply if the Trust later were considered to have acquired substantially all the interests of the project LLCs as part of the same plan, and the Vendors acquired Trust units). ...

The CVRs should be considered to be additional proceeds received on the disposition of Common Shares in an amount equal to the fair market value of the CVRs at the time of the disposition. ... If the CVRs are considered to be a debt obligation for the purposes of the ITA (notwithstanding that the amount ultimately payable under the CVRs is uncertain and unlimited), a Canadian Holder may be required to accrue as income the maximum amount payable under the CVRs held by them (generally in excess of the amount for which the CVRs were issued), in the taxation year of the receipt of the CVRs, in the period during which the CVRs are held, or on a disposition of the CVRs (including in connection with the receipt of a Redemption Amount). ...

Holders should consider whether the income from such finance activities is considered to be "passive". Whether such income is considered to be "passive" may depend in part on the ability of a non-U.S. corporation to meet certain requirements under the PFIC rules, the analysis of which Element has not performed. ...

For its taxation year commencing on January 1, 2019, the REIT does not expect to qualify as a REIT and may be considered a “SIFT trust.” If the REIT is considered a “SIFT trust” for its taxation year commencing on January 1, 2019, the REIT does not expect to have material “non-portfolio earnings.” ...

MI 61-101 As a result of the payment of fees to Macquarie as a financial advisor, Macquarie will be considered to receive a collateral benefit. ...