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Holder will be considered to be a taxable distribution in an amount equal to the fair market value of such shares. ...

Presumably the $175M third party debt owing by CAP REIT remains in place, which is considered to have been borrowed to acquire the ResREIT assets which CAP REIT still owns after the transaction. ...

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

The Amalco Redeemable Preferred Shares on Redemption will be considered to have disposed of for proceeds of disposition equal to the aggregate fair market value of the Hudbay Warrants received on the Redemption. ...

S. 86 will apply to such exchange so that a holder of IMZ 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 Chaparral Gold shares received on the exchange. ...

S. 86 will apply to such exchange so that a holder of Osisko 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 New Osisko shares received on the exchange. ...

Those who do not make and timely-file a valid election will be considered to have disposed of their shares on a non-rollover basis. ...

As financial lease agreements are not considered to be real estate assets and no elections have been made to purchase real estate assets, the 3% tax assessed on directly or indirectly held real estate will not be applicable. ...

S. 86 will apply to such exchange so that a holder of the Company 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 Deer Spring Holdings shares and TitanStar REIT units received on the exchange. ...

However, it is considered that the hotel business of the U.S. REIT (i.e., Lodging Enterprises) will qualify as a business of providing services rather than of renting real property, so that the income of the U.S. ...