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Partnership taxation/SIFT tax BPP LP and the Property Partnership would be considered to be "Canadian resident partnerships" and, therefore taxable as SIFT partnerships, if their central management and control were in Canada. ... Such GPs also intend to manage the affairs of the two partnerships so that, to the extent possible, they are not considered to carry on business in Canada (p. 40). ...

Because the right to receive Pan American shares under the CVRs is not absolute, the CVRs are considered to represent “boot” rather than share consideration for s. 85 election purposes. The cost of a Pan American share received under a CVR is considered to be equal to the FMV of a CVR received under the Plan of Arrangement. ...

Effect of repayment If the obligation to repay AcquisitionCo pursuant to the CRP Agreement arises before the Canadian Holder's filing-due date for its taxation year in its Common Shares were disposed of (or before the end of its fiscal period, if a partnership), the amount considered to be a repayment should be deemed to be a reduction in its proceeds of such disposition. If such obligation arises thereafter, the amount considered to be a repayment should be deemed to be a capital loss of the Canadian Holder from the disposition of a property by it at that time. Qualified investment The Loan should be considered to be a qualified investment for registered plans (except a deferred profit sharing plan to which ExxonMobil, or an employer that does not deal at arm's length with it, has made a contribution) provided that the ExxonMobil Shares are listed on a designated stock exchange. ...

Dispositions by partners on dissolutions The partners of each such dissolving Partnership (including the Upper Tier Subsidiary Partnerships, in the case of the dissolution of the Lower Tier Subsidiary Partnerships, and the Fund, in the case of the dissolution of the Upper Tier Subsidiary Partnerships) will be considered to dispose of their interests in the dissolving Partnership for proceeds of disposition equal to the amount of cash plus the fair market value of any other property distributed to them by the dissolving Partnership on the dissolution. ... For these purposes, U.S. taxes paid by a Subsidiary Partnership should generally be considered to have been borne by a particular Holder to the extent of the Holder’s share of such tax as determined in accordance with the Limited Partnership Agreement. ... As a result of the transaction, each such partnership will be considered to dispose of a USRPI. ...

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). ...