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XXXXXXXXXX; "US Treaty" means the Canada – United States Tax Convention (1980), as amended by the Protocols thereto. ...

It is a resident of the United States under the Canada-United States Tax Convention (1980) (the "U.S. ...

"Treaty" means the Convention between Canada and Country 2 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as amended. ...

With regard to the payment by DC in respect of existing DC Common Shares held by a Dissenting Shareholder as described in Paragraph 23: (a) subject to the application of subsection 55(2), the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from DC to the Dissenting Shareholder in respect of the purchase of such Dissenting Shareholder's DC Common Shares exceeds the paid-up capital of such shares immediately prior to their purchase; (b) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit 25% of the amount of any dividend deemed to have been paid as described in (a) to a Dissenting Shareholder who is a non-resident of Canada; and (c) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of the deemed dividend described in (a) from the proceeds of disposition of the DC Common Shares recognized by the Dissenting Shareholder as a result of such purchase of the DC Common Shares by DC, provided that the shares were held as capital property by the Dissenting Shareholder. ...

On the purchase by DC of DC Common Shares held by a Dissenting Shareholder as described in Paragraph 21: (a) subject to the application of subsection 55(2), the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from DC to the Dissenting Shareholder in respect of the purchase of such person's DC Common Shares exceeds the paid-up capital of such shares immediately prior to their purchase; (b) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit XXXXXXXXXX % of the amount of any such dividend deemed to have been paid to a Dissenting Shareholder who is a non-resident person of Canada; and (c) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of such deemed dividend from the proceeds of disposition of the DC Common Shares recognized by the Dissenting Shareholder as a result of the purchase of such shares by DC, provided that the shares were held as capital property by the Dissenting Shareholder. ...

On the purchase by DC of DC Common Shares held by a Dissenting Shareholder as described in Paragraph 22: (a) subject to the application of subsection 55(2), the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from DC to the Dissenting Shareholder in respect of the purchase of such person's DC Common Shares exceeds the paid-up capital of such shares immediately prior to their purchase; (b) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit 25% of the amount of any such dividend deemed to have been paid to a Dissenting Shareholder who is a non-resident person of Canada; and (c) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of such deemed dividend from the proceeds of disposition of the DC Common Shares recognized by the Dissenting Shareholder as a result of the purchase of such shares by DC, provided that the shares were held as capital property by the Dissenting Shareholder. ...

With regard to the payment by DC in respect of DC Common Shares held by a Dissenting Shareholder as described in Paragraph 22: (a) subject to the application of subsection 55(2), the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from DC to the Dissenting Shareholder in respect of the purchase of such Dissenting Shareholder's DC Common Shares exceeds the paid up capital of such shares immediately prior to their purchase; (b) subsections 212(2) and 215(9) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit 25% of the amount of any dividend deemed to have been paid as described in (a) to a Dissenting Shareholder who is a non-resident of Canada; and (c) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of the deemed dividend described in (a) from the proceeds of disposition of the DC Common Shares recognized by the Dissenting Shareholder as a result of such purchase of the DC Common Shares by DC, provided that the shares were held as capital property by the Dissenting Shareholder. ...

Y et GESTCO ont conclu une convention unanime entre actionnaires relativement à la participation de M. ...

With regard to the purchase by DC of Existing DC Shares held by a Dissenting Shareholder as described in Paragraph 21 and subject to the application of subsection 55(2): (a) the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from DC to the Dissenting Shareholder in respect of the purchase of such person's shares exceeds the PUC of such shares immediately prior to their purchase; (b) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit 25% of the amount of any such dividend deemed to have been paid to a Dissenting Shareholder who is a non-resident person; and (c) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of such deemed dividend from the proceeds of disposition of the Existing DC Shares recognized by the Dissenting Shareholder as a result of the purchase of such shares by DC provided that the shares were held as capital property by the Dissenting Shareholder. ...

Subject to the application of §55(2) to Dissenting Shareholders that are corporations resident in Canada, §§84(3)(a) and (b) will apply to deem XXXXXXXXXX to have paid and any Dissenting Shareholder to have received, on a separate class of shares comprising the XXXXXXXXXX Common Shares of all Dissenting Shareholders, a dividend equal to the amount by which any payment from XXXXXXXXXX to the Dissenting Shareholder in respect of the repurchase of such person's shares exceeds the PUC of such shares immediately prior to their repurchase; §212(2) and §215(1) will apply (subject to the provisions of any applicable income tax convention) to require XXXXXXXXXX to withhold and remit 25% of the amount of any such dividend deemed to have been paid to a Dissenting Shareholder who is a non-resident person; and §(j) of the definition of "proceeds of disposition" in §54 will apply to exclude the amount of such deemed dividend from the proceeds of disposition of the XXXXXXXXXX Common Shares recognized by the Dissenting Shareholder as a result of repurchase of such shares by XXXXXXXXXX. ...