Search - considered

US Holdco is expected to make the election under Code s. 1059(c)(4) to have its basis in the shares of Regional Energy considered to be their much higher fair market value, for purposes of determining whether dividends from Regional Energy during the first two years of US Holdco's indirect investment therein are an extraordinary dividend (otherwise potentially giving rise to a negative basis gain). ...

A U.S. holder who receives DREAM shares under the Arrangement should be considered to have received a taxable distribution, so that if Dundee is not treated as a PFIC, such U.S. holder generally will be required to include the fair market value of DREAM shares in income to the extent of Dundee's current or accumulated earnings and profits. ...

S. 97(2) exchange Holders of True North Partnerships Class B Units who exchange their Units for Redeemable Units of the applicable partnership and who jointly elect under s. 97(2) will be considered to have disposed of their units for an elected amount which complies with s. 97(2). ...

A Resident Shareholder that transfers New Common Shares under the Arrangement to the Purchaser for the Consideration including any portion of the Contingent Payment Received, will be considered to have disposed of such New Common Shares for proceeds of disposition equal to the amount of the aggregate Consideration, including any portion of the Contingent Payment Amount received. ...

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. ...