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TransCanada Trust -- summary under Sub Trust Notes

Automatic Exchange An exchange of Trust Notes — Series 2017-A by a Non-Resident Holder for rights to acquire TCPL Exchange Preferred Shares pursuant to an Automatic Exchange will result in a disposition of such Trust Notes — Series 2017-A for purposes of the Tax Act for proceeds equal to the fair market value of the TCPL Exchange Preferred Shares which the Non-Resident Holder has the right to acquire, not including any amount considered to be interest. ...

Central Fund/Sprott -- summary under MFC Conversion to MFT

U.S. tax consequences Exchange The exchange of Class A Shares for Trust Units pursuant to the Arrangement should be treated as one step in a series of integrated transactions that, considered together, qualify as a reorganization for U.S. federal income tax purposes. ...

Banro -- summary under Debt into common equity

Canadian tax consequences Disposition by Secured Noteholders A Resident Holder of Secured Notes will be considered to have disposed of its Secured Notes upon the exchange of Secured Notes for New Equity and the Resident Holder's pro rata share of the Affected Banro Unsecured Cash Pool (collectively the "Secured Note Consideration") on the Implementation Date. ...

Thomson Reuters -- summary under S. 86 cash distributions

Treatment of opted-out shareholders The Return of Capital Transaction is not considered to be pursuant to a plan to periodically increase any shareholder’s proportionate interest in the Corporation’s assets or earnings and profits. ...

First Capital -- summary under Domestic REITs

S. 97(2) Tax Election A Holder that validly elects to receive Exchangeable LP Units and the Ancillary Rights in exchange for Common Shares will, unless such Holder files a Tax Election Form under Subsection 97(2) of the Tax Act be considered to have disposed of such Common Shares for proceeds of disposition equal to the aggregate of (i) the fair market value at the Effective Time of any Exchangeable LP Units received by the Holder on the exchange, and (ii) the fair market value at the Effective Time of the Ancillary Rights received by the Holder on the exchange. ...

H&R REIT -- summary under Releveragings

") On the Portfolio LP Distribution, Portfolio LP will be considered to have disposed of the notes for proceeds of disposition equalling their fair market value, so that it will realize a capital gain (or a capital loss) to the extent that such proceeds of disposition exceed (or are less than) the adjusted cost base of such U.S. ... On the Portfolio LP Trust Distribution, the REIT will be considered to acquire the PHP U.S. ...

Loral/ Telesat -- summary under Delaware etc. Mergers

The exchanges by the Loral shareholders for shares of Telesat Corporation or units of Telesat Partnership were considered to be non-recognition transactions under Code s. 351 or s. 721. ... Telesat Corporation believes that such interpretation is consistent with the rationale expressed by the CRA for its published administrative position in this regard, so that there would be no net income inclusion to the partnership, and it was considered appropriate that there also should be no net inclusion to Telesat Corporation. ...

S2-F1-C2 - Retiring Allowances -- summary under Retiring Allowance

Human rights violations 2.18 Similarly, general damages relating to human rights violations can be considered unrelated to a loss of employment. ... Payments in lieu 2.21 A payment in lieu of earnings for a period of reasonable notice of termination that is made under the explicit or implied terms of an individual’s employment is considered employment income. However, where a payment of damages arising from the loss of employment includes an amount in respect of the period of reasonable notice, this amount will be considered a retiring allowance. ...

S2-F3-C2 - Benefits and Allowances Received from Employment -- summary under Subparagraph 6(1)(b)(v)

S2-F3-C2- Benefits and Allowances Received from Employment-- summary under Subparagraph 6(1)(b)(v) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(v) Reasonable travel allowance 2.63...In general, expenses normally incurred while travelling from one place to another, including food, accommodation, and incidentals, are considered travel expenses. 2.64...[A]n allowance that approximates the reasonable out-of-pocket expenses the employee will incur while travelling for work is generally considered reasonable. ...

S1-F2-C2 - Tuition Tax Credit -- summary under Paragraph 118.5(1)(d)

S1-F2-C2- Tuition Tax Credit-- summary under Paragraph 118.5(1)(d) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(d) Examinations taken in order to begin study in a profession or field, such as a medical college admission test, are not considered to be an occupational, trade, or professional examination for purposes of paragraph 118.5(1)(d). In contrast, fees paid by a foreign-trained lawyer or law graduate to the National Committee on Accreditation (NCA) to undertake a challenge examination that is required to obtain a Certificate of Qualification to access the bar admission process of a Canadian law society would be considered an occupational, trade, or professional examination for purposes of paragraph 118.5(1)(d). ...

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