Search - consideration

The Trust had acquired the Real Property from Canco 2 in consideration for the assumption of Loan 1, being a mortgage owing to the third party that had sold the Real Property to Canco 2, and Loan 3, being an unsecured loan owing to Finco, a wholly-owned subsidiary of the Beneficiary. ... Proposed transaction The Trustee will distribute the Real Property (including lease) to the Beneficiary, on condition that the Beneficiary assume Loan 1, Loan 2, and Loan 3, which will be the sole consideration given for. ...

Parent assumption of SERP Obligations Pursuant to the terms of a Consent, Assignment and Release Agreement that will be entered into with each Pensioner, each Pensioner will permit Opco to assign to Parent, and Parent to assume from Opco, the SERP Obligations, and Opco will assign to Parent, and Parent will assume, all of the SERP Obligations for no consideration. ... Wind-ups Opco will transfer certain of its assets, if any, that have accrued gains to Holdco for cash consideration equal to the FMV of such assets so transferred. ...

For example, Father transfers shares of Opco (a small business corporation whose shares are eligible for the CGE) to his children in consideration for a note that is payable over 10 years, claims the capital gains reserve, but does not claim the CGE. The children transfer the Opco shares to a new Holdco in consideration for a note of Holdco, with a view to Opco dividends funding note repayments. ...

Proposed transactions Bco will incorporate a new wholly-owned subsidiary (“Lossco”) and subscribe for Lossco common shares for nominal consideration. Cco will incorporate a new wholly-owned subsidiary (“Newco 1”) and subscribe for Newco 1 common shares for nominal consideration. ...

Ss. 87(9)(a.4) and (c) apply so that the cost of the shares of Amalco held by Parentco are not derived from the value of the consideration given. ... CRA indicated that in Scenario 1, the shares received by Parentco from Amalco are subject to the application of ss. 87(9)(a.4) and (c), so that the cost of the shares of Amalco held by Parentco will not be derived from the value of the consideration given (that is the shares issued by Parentco to acquire the shares of Amalco) to the former shareholders of Targetco. ...

Preliminary transactions After redeeming the Class B and C preferred shares through the issuance of demand promissory notes (with no resulting deemed dividend or capital gain to the estate), ACo will purchase for cancellation (in consideration for issuing a demand promissory note) a sufficient such number of its Class A shares to result in a refund of its eligible refundable dividend tax on hand, or its non-eligible refundable dividend tax on hand, balances. ... Proposed transactions The Estate will transfer its remaining Class A shares (electing under s. 85(1)) to a newly-incorporated corporation formed by it (“Newco”) in consideration mostly for a note (the “Note 6”) with a principal amount and FMV equal to the lesser of such shares’ current FMV and their (stepped-up) ACB, and for a Class A (common) share of Newco. ...

Preliminary transactions Opco redeemed Class E shares in consideration for Note 1 and designated the resulting deemed dividend as an eligible dividend, with the estate carrying back the resulting capital loss to it under s. 164(6). ... Proposed transactions The estate will transfer its Class A shares of Opco 2 to a corporation newly incorporated by it (“Newco”) in consideration for a note (“Note 5”) and for Class B non-voting redeemable retractable shares, electing under s. 85(1) and with a price adjustment clause. ...

Proposed transactions The estate will transfer its Class A and Class E shares of the Corporation to a newly-incorporated corporation (“Newco” – whose voting common shares are held by it) in consideration for Class A common shares and a Newco and two non-interest-bearing notes (“Note 1” and “Note 2”), electing under s. 85(1). ... Trusts 1, 2 and 3 will transfer their Class J shares of the Corporation to Newco in consideration for Class F shares of Newco, electing under s. 85(1). ...

They then implemented a divisive reorganization of Opco under which B disposed of her Opco common shares to Newco (newly-incorporated by her) in consideration for Newco common shares, Opco disposed of a portion of its business property to Newco in consideration for Newco preferred shares and the two shareholdings were cross-redeemed for notes that were then set off. ...

The Corporation will redeem the Class A Preferred Shares in consideration for a demand noninterest bearing promissory note, designate a portion (not exceeding its GRIP account) as an eligible dividend pursuant to s. 89(14) and report a resulting capital loss, which will be carried back under s. 164(6). ... The Estate will transfer the Class A Common Shares to a “Newco” formed by it in consideration for Newco common shares, electing under s. 85(1). ...