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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. ...

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. ...