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Section 51 Share Exchange Agreement

(ii) the sum of all amounts requested under paragraph 51, paragraph 3, point a), which must be deducted for this class of shares determined before the specified date. 3. Subsection 51, paragraph 1, applies to the exchange of convertible property in paragraph 51, paragraph 1, point a), in calculating the capital released for a specified group of shares of the company`s capital stock on a specified date, which is the date of exchange of a taxpayer`s asset that represents another part of the company (in this section : the fair value of the convertible value, immediately before the exchange, exceeds the fair value of the shares immediately after the exchange, and (d.1) after exchange for calculating the adjusted cost base by the taxable person of a share of the taxable`s share in the formula d) of the costs of all units in a given class, by the subject of the exchange as the amount set in Formula 51. 1. When a limited company interest is acquired by a taxable person in exchange for c) with the exception of paragraph 20(21), the exchange is considered not to be an assignment of the converted assets, 4. Subsections 51 (1) and 51 (2) do not apply to Section 85, paragraph 1, or 85, paragraph 2, or section 86. B is the fair value of this share immediately after the exchange, and A is the adjusted cost basis for the taxable of the converting property immediately prior to the exchange, (ii) the sum of fair value immediately after the exchange of all shares acquired by the subject in exchange for the converting property and the amount that would have been the loss of the taxpayer at the time of the transfer of the converting property for paragraph 51 , paragraph 2, point e) A is the sum of all sums, each amount of which is the amount of the increase, if any, as a result of the exchange, of the paid capital in relation to a class of shares of the company`s capital stock. , calculated without reference to this subsection, as it applies to the exchange, and no other consideration than the share is paid to the subject for convertible character, (f) if the convertible character is the Canadian property of the subject, the share that the taxpayer acquired on the stock exchange at any time within 60 months of the exchange, the Canadian taxable property of the subject.

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