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Results 1061 - 1070 of 8029 for consideration
Ruling
1999 Ruling 9901513 - BUTTERFLY REORGANIZATION
On incorporation, one class A common share will be issued to XXXXXXXXXX for consideration of U.S. ... The liabilities assumed by the Transferee Corporations will be assumed as consideration for particular properties. ... The interest rate on the Excess Notes will exceed the rate of interest on the debt assumed as consideration for these issues. 44. ...
Ruling
1999 Ruling 9917383 - REORGANIZATION
XXXXXXXXXX will not receive any consideration for these transfers. The purpose of these transactions is to comply with XXXXXXXXXX land transfer tax requirements with respect to the transfers of the properties. 27. ... As consideration for the transfer, XXXXXXXXXX Holdings will give XXXXXXXXXX Trustco the sum of $XXXXXXXXXX. 29. ... As consideration for the transfer, XXXXXXXXXX Holdings will give XXXXXXXXXX Trustco the sum of $XXXXXXXXXX. 30. ...
Ruling
2019 Ruling 2019-0811641R3 - Multi-wing split up butterfly
In particular, Sibling 1 will transfer his XXXXXXXXXX common shares of DC to TC1 in exchange for TC1 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred; Sibling 2 will transfer his XXXXXXXXXX common shares of DC to TC2 in exchange for TC2 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred; and Sibling 3 will transfer her XXXXXXXXXX common shares of DC to TC3 in exchange for TC3 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred. ... For greater certainty, there will be no non-share consideration on the transfer of DC Sub shares. 38. ... The agreed amount in respect of the shares of DC Sub so transferred will not be greater than their FMV nor will it be less than the FMV, at the time of disposition, of the non-share consideration received as consideration. ...
Ruling
2023 Ruling 2022-0958241R3 - Public Spin-Off Butterfly
Each holder of DC Equity Incentive Securities will dispose of such holder’s Butterfly Proportion thereof to SpinCo in consideration for corresponding SpinCo Equity Incentive Securities, and will dispose of the remaining portion thereof to DC in consideration for corresponding DC New Equity Incentive Securities. ... Every Participant will receive FMV consideration from SpinCo in the form of one SpinCo Common Share for every transferred DC Preference Share. ... DC will redeem for cancellation all of the outstanding DC Preference Shares held by SpinCo and will issue to SpinCo, as sole consideration therefor, the DC Redemption Note. ...
Technical Interpretation - External
6 November 1989 External T.I. 89M11185 F - Source Deductions Waivers
Chris Martin of Consumer and Corporation Affairs Canada for your consideration and direct reply. ...
Ministerial Correspondence
6 October 1989 Ministerial Correspondence 89M10424 F - Proposed Conference Attendance 1990-1991
Cockell 957-9226 SUBJECT: PROPOSED CONFERENCE ATTENDANCE 1990-1991 Consideration could be given to sending one person from this Division (Director or Chief) to the Canadian Tax Foundation Annual Conference. ...
Administrative Letter
29 November 1989 Administrative Letter 89M11286 F - Transmission of Documents
Jolie of your office, we are forwarding for your consideration and reply the yellow file folder containing 24(1) letter of October 31, 1989 addressed to the Honourable Otto Jelinek. ...
Miscellaneous severed letter
10 October 1989 Income Tax Severed Letter ACC8519 - GST Implications on Income Tax
Attached for your consideration and comment is a copy of a Department of Finance memorandum dated October 5, on this topic. ...
Miscellaneous severed letter
6 November 1989 Income Tax Severed Letter ACC8494 - Source Deductions
Mancino, Director, Source Deductions Division (tel. 954-1284) for consideration and reply. ...
Miscellaneous severed letter
6 October 1989 Income Tax Severed Letter ACC8618 - Proposed Conference Attendance 1990-1991
Cockell 957-9226 PROPOSED CONFERENCE ATTENDANCE 1990-1991 Consideration could be given to sending one person from this Division (Director or Chief) to the Canadian Tax Foundation Annual Conference. ...