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It should be eligible for benefits under the Canada-US Convention provided that its units are primarily and regularly traded on the TSX. Interest on the notes of HealthLease US held by the REIT (which should be characterized as debt rather than equity based on certain interest rate and debt feasibility studies) should be exempt from US withholding tax under the Convention. ...

US tax consequences If Primaris has made an election to be classified as a partnership for Code purposes, non-resident holders receving distributions from Primaris that are subject to Canadian withholding tax may be denied the benefit of reduced rates under the Canada-US Convention as a result of Art. IV(7)(b) of the Convention. Subject to the PFIC rules, a US unitholder will realized a capital gain or loss on a disposition of units pursuant to the Offer based on the difference the US-dollar value of the Canadian dollars received pursuant to the Offer and the adjusted tax basis of the units. ...

Interest on any note owing by Holding GP to the Fund should not be subject to US withholding tax provided that the Fund unitholders are able to establish that such interest is exempt under the Canada-US Convention or under the portfolio interest exemption. ...

Non-Residents A dividend, such as the Dividend, paid or credited or deemed to be paid or credited to a Non-Resident Holder will be subject to Canadian withholding tax at the rate of 25%, subject to any reduction in the rate of withholding to which the Non-Resident Holder is entitled under any applicable income tax convention. ...

Treaty withholding DRI Healthcare is expected to be eligible for benefits under the United States Tax Convention with Ireland and will generally not be subject to any U.S. withholding taxes on such U.S. ...

" Canadian Treaty exemption Under Canada-Peru Tax Convention, Rio Alto Shareholders who are resident or deemed resident in Canada for the purpose of that Treaty will be exempt from Peruvian tax on any gain arising from the exchange. ...

" Commercial Trust The Commercial Trust will be treated as a corporation resident in Canada; and it is expected that it will be eligible for the benefits of the Canada-US Income Tax Convention (the "Treaty"), so that interest on the US Holdco Note will be exempt from withholding under the Treaty. ...

BBP LP may allocate items of income, gain, loss, and deduction using a monthly convention, whereby any such items recognized in a given month by it are allocated to unitholders as of a specified date of such month. ...

Non-resident unitholders A Non-Resident Trust Unitholder will not be subject to tax under the Tax Act on any capital gain realized on the disposition of Trust Units under the Redemption, unless (i) the Trust Units disposed of are "taxable Canadian property" (as defined in the Tax Act) of the Non-Resident Trust Unitholder at the time of the disposition, and (ii) the Non-Resident Trust Unitholder is not exempt from taxation in Canada on the disposition of such shares pursuant to an applicable income tax treaty or convention. ...

A non-resident Shareholder will not be subject to tax under the Tax Act in respect of any capital gain realized on the disposition of Shares under the Offer unless the Shares are "taxable Canadian property" to the Non-Resident Shareholder at the time of such sale and such gain is not otherwise exempt from tax under the Tax Act pursuant to the provisions of an applicable income tax convention (if any). ...