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Pacific Exploration -- summary under Debt into common equity

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. ...

Jackpotjoy/Intertain -- summary under Exchangeable Share Acquisitions

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. ...

Alignvest/Trilogy -- summary under Subscription

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. ...

GFL -- summary under Prepaid Share Purchase

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. ...

S4-F2-C2 - Business Use of Home Expenses -- summary under Paragraph 18(12)(a)

A in his home to perform the administrative functions of his business will be considered Mr. ... However, a work space in respect of a business which normally requires infrequent meetings or frequent meetings at irregular intervals will not meet this requirement. 2.16 A work space in the home that is used by a doctor to meet one or two patients a week is an example of a work space that would not be considered to be used on a regular and continuous basis for meeting patients. ...

S4-F16-C1 - What is a Partnership? -- summary under Section 96

" Joint venture with profit sharing but no co-ownership 1.22 A joint venture agreement, whereby two or more persons agree that each provides their own property, performs a specific task and receives a specific division of profits from such a task, may be considered a partnership as regards such profits. However, if the property is not held under joint tenancy or tenancy in common, it is not considered to be partnership property. ...

S4-F7-C1 - Amalgamations of Canadian Corporations -- summary under Subsection 1100(2.2)

This anti-avoidance provision will apply where a new corporation would be considered not to deal at arm's length with a predecessor corporation as a result of a transaction or series of transactions the principal purpose of which may reasonably be considered to have been to cause subsection 1100(2.2) or 1102(14) of the Regulations to apply to a given amalgamation. ...

S5-F1-C1 - Determining an Individual’s Residence Status -- summary under Subsection 120(1)

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Subsection 120(1) Summary Under Tax Topics- Income Tax Act- Section 120- Subsection 120(1) "An individual who is resident in more than one province on December 31 of a particular tax year will be considered to be resident only in the province in which the individual has the most significant residential ties, for purposes of computing his or her provincial tax payable. ...

S1-F1-C1 - Medical Expense Tax Credit -- summary under Paragraph 118.2(2)(i.1)

S1-F1-C1- Medical Expense Tax Credit-- summary under Paragraph 118.2(2)(i.1) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(i.1) To the extent that items such as bed clothing, disposable gloves for caregivers, body ointments and baby wipes are generic and not designed for use by incontinent persons, the expenses would not be considered medical expenses under paragraph 118.2(2)(i.1). ...

S1-F1-C1 - Medical Expense Tax Credit -- summary under Paragraph 118.2(2)(l.9)

S1-F1-C1- Medical Expense Tax Credit-- summary under Paragraph 118.2(2)(l.9) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(l.9) The requirement that the therapy be administered under the general supervision of a medical doctor, psychologist or occupational therapist is not considered to be met where the medical practitioner is merely monitoring a patient who is undergoing therapy. ...

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