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Results 1051 - 1060 of 8029 for consideration
Ruling

30 November 1996 Ruling 9633793 - BUTTERFLY

As consideration for this purchase, Opco issued a non-interest bearing demand promissory note payable to the Estate having a principal amount and fair market value equal to the fair market value of the shares purchased. ... Other than the share consideration described above, no other consideration will be received by Son, Daughter 1, Daughter 2 and Son-in-law as a consequence of the amalgamation. ... No other consideration will be received by either Daughter 2 or Son-in-law in respect of such transfers. ...
Ruling

2003 Ruling 2003-0002873 - Butterfly Transaction - Papillon

ACO will subscribe for XXXXXXXXXX Newco 1 Class A shares of Newco 1 for a total cash consideration of $XXXXXXXXXX. BCO will subscribe for XXXXXXXXXX Newco 2 Class A shares of Newco 2 for a total cash consideration of $XXXXXXXXXX. 15. ... All of these sales will be done for cash consideration and with arm's length parties. 16. ...
Ruling

2003 Ruling 2002-0162973 - Split up Butterfly

R will assign the indebtedness in the principal amount of $XXXXXXXXXX represented by the promissory note executed by Holdco in favour of R ("Holdco Note 1") to Rco in consideration for a similar promissory note executed by Rco in favour of R. ... For greater certainty, Holdco will transfer R's Mortgage to Rco in consideration for XXXXXXXXXX Class "C" preferred shares of Rco having an aggregate redemption value equal to the outstanding principal amount of R's Mortgage. ... For greater certainty, Holdco will transfer Property 1 to Tco pursuant to section 85 in consideration for XXXXXXXXXX Class "C" preferred shares of Tco having an aggregate redemption value equal to the FMV of Property 1. ...
Ruling

2000 Ruling 9927533 - TAKE-OVER, BUMP AND SALE

As consideration for such transfer, XXXXXXXXXX/K will issue a nominal number of common shares. ... As consideration for such transfer, New XXXXXXXXXX/I will assume certain liabilities of XXXXXXXXXX/I and will issue common shares. ... The consideration payable by XXXXXXXXXX/M under the Offer for each XXXXXXXXXX/C Share will be a specified amount of cash. ...
Ruling

2022 Ruling 2022-0933091R3 - Single-Wing Split-Up Butterfly

Each Class A Special Share will be redeemable and retractable at an amount equal to the FMV of the property acquired in exchange for the share less the non-share consideration given (plus any declared but unpaid dividends thereon), subject to a price adjustment clause. ... As consideration, TC will issue the TC Redemption Note having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class A Special Shares so redeemed by it. ... As consideration, DC will issue to TC the DC Non-CDA Purchase Note having a principal amount and FMV equal to the aggregate FMV of such Common Shares and Class "C" Preference Shares purchased for cancellation. ...
Ruling

2014 Ruling 2012-0432441R3 - Butterfly reorganization

The class F preferred shares are redeemable and retractable for a redemption amount equal to the FMV of the consideration for which they were issued. ... "Promissory Note 1" means the non-interest-bearing promissory note that Newco will issue to DC in consideration for the redemption of the class F preferred to be issued to DC in partial consideration for the Distribution as further described in Paragraph 21. ... Immediately after the Distribution, Newco will redeem all of the class F preferred shares held by DC in consideration for Promissory Note 1. ...
Ruling

2013 Ruling 2013-0507291R3 - Supplemental Ruling

The units of itself that REIT #1 shall receive, as described in 51 above, will be cancelled for no consideration. 53. ... The units of itself that REIT #1 shall receive, as described in 62 above, will be cancelled for no consideration. 64. ... The units of itself that REIT #1 shall receive, as described in 73 above, will be cancelled for no consideration. 75. ...
Ruling

2015 Ruling 2014-0552871R3 - Split-Up Butterfly

Shareholder2 used the consideration received on the sale of the shares of Canco1 to repay its existing indebtedness to DC in the approximate amount of $XXXXXXXXXX. ... TC2 will acquire from TC1, the part of the Collectibles owned by TC1 for FMV consideration which the TCs have determined to be $XXXXXXXXXX plus tax. 58. ... TC1 will acquire from TC2 its interest in the Canco1 Loan Note for FMV consideration which the TCs have determined to be $XXXXXXXXXX. ...
Ruling

2006 Ruling 2006-0195411R3 - Income Trust Reorganization

HOLDCO will settle all inter-company accounts and will dispose of its net current assets and liabilities, with the exception of the HOLDCO notes, to AMALCOA for fair market value consideration. ... The FUND will incorporate MFC by subscribing for one MFC Common Share for nominal consideration. ... In accordance with the Securities Document, the FUND will subscribe for a number of MFC Class A Shares equal to the number of FUND Units then outstanding for nominal cash consideration to be determined at a future date. ...
Ruling

2005 Ruling 2004-0093021R3 - Split-up Butterfly

Opco will subscribe for XXXXXXXXXX New Opco Common Shares for a total consideration of $XXXXXXXXXX. ... As consideration for the transfer, Interco will either issue additional shares to Opco or non-share consideration. 47. ... Dco will subscribe for XXXXXXXXXX Dco2 Common Shares for a total consideration of $XXXXXXXXXX. ...

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