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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. ...

Automatic Conversion A conversion of Notes into Conversion Preferred Shares pursuant to an Automatic Conversion will result in a disposition of such Notes for purposes of the Tax Act for proceeds equal to the fair market value of the Conversion Preferred Shares which the Non-Resident Holder acquires, not including any amount considered to be interest. ...

Taxable exchange under the Arrangement A Holder will generally be considered to have disposed of such Preferred Share for proceeds of disposition equal to the fair market value of any Redemption Note issued on redemption thereof. ...

However, during this discussion Torys stated that BPY had considered structuring the transaction as a plan of arrangement or a tender offer but that, because a redemption provided BPY with the flexibility to best organize the activities of the Trust consistent with the operations and ownership of BPY's other core office assets, BPY was not prepared to proceed with the Transaction under such alternative transaction structures. ...

Epsilon shareholders A Resident Shareholder will not be considered to have disposed of his or her common shares or to have realized a taxable capital gain or loss by reason only of the domestication. ...

U.S. tax consequences (per Summary) Under current U.S. federal income tax law, a corporation generally will be considered to be resident for U.S. federal income tax purposes in its place of organization or incorporation. ...

Accordingly, the Russian tax authorities may seek to assert that Intergeo Cyprus should be considered to be a "conduit company" and be denied benefits under the Cyprus-Russia Tax Treaty, resulting in 15% Russian withholding tax. ...

The reorganization is considered to likely qualify as a Code s. 368(a) reorg in light inter alia of SpinCo representing less than 10% of Sulliden's net assets. ...