On October 1, 2025, Maple Leaf Foods Inc (“Maple Leaf Foods”) announced the completion of the spin-off of its pork operations into Canada Packers Inc. (“Canada Packers”) (collectively with Maple Leaf Foods, the “Companies”), implemented by way of statutory plan of arrangement (the “Arrangement”).
Reference is made to Maple Leaf Foods’ management information circular dated May 1, 2025 (the “Circular”) available on Maple Leaf Foods’ SEDAR+ profile at www.sedarplus.ca for more information with respect to the Arrangement.
Pursuant to the Arrangement, Maple Leaf Foods shareholders retained their interest in Maple Leaf Foods common shares and received a pro rata allocation of Canada Packers common shares. Under the Income Tax Act (Canada), the aggregate adjusted cost base to a Maple Leaf Foods shareholder immediately before the Arrangement should be allocated between such shareholder’s Maple Leaf Foods common shares immediately after the Arrangement and such shareholder’s Canada Packers common shares received pursuant to the Arrangement proportionately based on the relative fair market values of such shares at the time of the Arrangement. The allocation set out below is based on the Companies’ estimate of the fair market values of each Company. The Companies believe the allocation set out below is reasonable for Canadian income tax purposes. However, such allocation is not binding on shareholders or the Canadian tax authorities.
In connection with the Arrangement, the aggregate adjusted cost base to a Resident Shareholder (as defined in the Circular) of Maple Leaf Foods common shares held immediately before the Arrangement may be allocated to such shareholder’s post-Arrangement Maple Leaf Foods common shares and Canada Packers common shares as follows:
- 88.14% to the Maple Leaf Foods common shares; and
- 11.86% to the Canada Packers common shares.
Please refer to the section “Certain Canadian Federal Income Tax Considerations” in the Circular for further information regarding the Canadian federal income tax consequences to shareholders as a result of the Arrangement. The information contained herein is subject to the discussion in the section “Certain Canadian Federal Income Tax Considerations” in the Circular, and all of the assumptions, qualifications and limitations in that section of the Circular are applicable to the information contained herein. This notice is not, and is not intended to be, legal or tax advice. Shareholders should consult their own legal or tax advisors in light of their particular circumstances.