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Non-residents Non-residents who do not dispose of their BPO Common Shares pursuant to the Offer are cautioned that BPO Common Shares that are not listed on a ‘‘designated stock exchange'' at the time of their disposition will be considered ‘‘taxable Canadian property'' if at any time within the 60-month period immediately preceding the disposition, more than 50% of the fair market value of the BPO Common Shares was derived directly or indirectly from Canadian real property etc. ...

The U.S. tax disclosure discusses the risk that U.S. holders would receive rollover treatment – on the basis that their debt holdings are “securities,” or that the Plan would be considered to be a recapitalization. ...

Canadian tax consequences Exchange for Jackpotjoy Shares An Intertain Shareholder who exchanges Intertain Shares for Jackpotjoy Shares will be considered to have disposed of such Intertain Shares for proceeds of disposition equal to the fair market value. ...

Canadian tax consequences Redemption Those whose Class A Restricted Voting Shares are redeemed by the Corporation will be deemed to have received a dividend equal to the amount, if any, by which the aggregate Class A Restricted Voting Share redemption price paid exceeds the shares’ paid-up capital, and will be considered to have disposed of such shares for proceeds of disposition equal to the aggregate redemption price paid to such Resident Holder, less the amount of any such deemed dividend. ...

DFA rules The Canadian tax disclosure diffidently suggests that since the fair market value of the subordinate voting shares delivered on settlement of the purchase contract can be considered to be determined solely by reference to a change in the fair market value of the subordinate voting shares over the term of the agreement, the derivative forward agreement rules should not apply to the settlement of the purchase agreement so as to require the inclusion of all or a portion of the amount by which the fair market value of the subordinate voting shares received under the purchase contract exceeds the purchase price for the purchase contract. ...