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Results 1081 - 1090 of 8030 for consideration
Ruling

2005 Ruling 2005-0113301R3 - Butterfly

As sole consideration, Transferee 1 will issue to Trust1 XXXXXXXXXX Common shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC so transferred to Transferee 1. 29. ... As sole consideration, Transferee 3 will issue to Sib3 XXXXXXXXXX Common shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC so transferred to Transferee 3. 37. ... Each of the 5 Transferees will subscribe for one (1) Common share of its respective SubCo for cash consideration of $XXXXXXXXXX. ...
Ruling

1998 Ruling 9825963 - INTERNAL REORGANIZATION

As consideration for the transfer, XXXXXXXXXX will receive an increased partnership interest. 49. ... As sole consideration for the transferred XXXXXXXXXX Common Shares, Newco 1 will issue to XXXXXXXXXX. ... As sole consideration for the transferred XXXXXXXXXX Common Shares, XXXXXXXXXX will issue to XXXXXXXXXX Common Shares. ...
Ruling

2020 Ruling 2020-0853221R3 - Split-up butterfly: investment company

These shares have a non-cumulative dividend right of up to XXXXXXXXXX% per annum on the consideration received by DC upon issuance of the shares. ... Sibling 1 will subscribe for 100 TC1 Common Shares for aggregate consideration of $XXXXXXXXXX. 16. ... Sibling 2 will subscribe for XXXXXXXXXX TC2 Common Shares for aggregate consideration of $XXXXXXXXXX. 19. ...
Ruling

2012 Ruling 2010-0355941R3 - reverse subsidiary merger - 87(1) & 87(11)

As consideration for the Target Loan, Target issued a promissory note to Subco, having a principal amount of $XXXXXXXXXX (the "Target Note"). ... (c) Target subscribed for common shares of Newco for total cash consideration of $XXXXXXXXXX. ... As consideration for the transfer, Subco issued its common shares to Acquireco having an aggregate FMV equal to the aggregate FMV of all of the Target common shares so received by Subco. ...
Ruling

2009 Ruling 2008-0289771R3 - Loss Consolidation

Whether loss consolidation transactions acceptable where voting power of controlling party in one of the affiliated corporations is disproportionate to participating equity interest and consideration for the losses is given. 4. ... Lossco holds Class 5 preferred shares of Lossco Sub (the "Lossco Sub Preferred Shares") which it received as consideration for the previous transfer of the Portfolio to Lossco Sub. ... Opco will subscribe for XXXXXXXXXX Newco Class II Common Shares in consideration for a cash contribution equal to the fair market value of the XXXXXXXXXX Newco Class I Common Shares held by Lossco. ...
Ruling

2015 Ruling 2014-0548621R3 - Post Mortem Pipeline Planning

As consideration for all the redemptions described in Paragraph 9, the Corporation issued Debt1 to the Trust. 11. ... Upon incorporation of Newco, the Estate will subscribe for 1 Class A common share for $XXXXXXXXXX cash consideration. 25. ... The Trust will transfer XXXXXXXXXX Class F preferred shares and XXXXXXXXXX Class I preferred shares of the capital stock of the Corporation to Newco in consideration for PN1. ...
Ruling

2012 Ruling 2012-0464501R3 - Post-mortem planning

Estate will receive as consideration Note 1 issued by Newco for an amount equal to the FMV of the Class A shares of the capital stock of Amalco as at the date of X's death. ... Estate will receive as consideration Note 2 issued by Newco for an amount equal to the FMV of the Class C shares of the capital stock of Amalco as at the date of X's death. 27. ... Y will receive as consideration one Class G preferred share of the capital stock of Newco with a redemption value equal to the FMV of the common share of the capital stock of Amalco transferred. ...
Ruling

2013 Ruling 2013-0501811R3 - Internal Reorganization - 55(3)(a)

In consideration for the Aco shares transferred, ParentCco will pay to ParentAco $XXXXXXXXXX in cash. ... In consideration for the Aco shares transferred, Cco will pay to ParentCco $XXXXXXXXXX in cash, and will issue to ParentCco one common share of its capital stock. Cco will use its available cash on hand and cash borrowed from related entities to fund the $XXXXXXXXXX cash consideration paid to ParentCco. ...
Ruling

2015 Ruling 2015-0604851R3 - Post Mortem Pipeline Planning

As consideration for all the redemptions described in Paragraph 9, the Corporation issued Debt1 to the Trust. 11. ... Upon incorporation of Newco, each of the Beneficiaries will subscribe for 1 Class A common share for $XXXXXXXXXX cash consideration. 25. ... The Trust will transfer XXXXXXXXXX Class F preferred shares and XXXXXXXXXX Class I preferred shares of the capital stock of the Corporation to Newco in consideration for PN1. ...
Ruling

2012 Ruling 2011-0401811R3 - Post-Mortem Planning

Each Class G preferred share will be redeemable and retractable for an amount (the “Redemption Amount”) equal to the FMV of the consideration received by Newco upon the issuance of such share. ... The Trust will receive as consideration: a. Note 1 issued by Newco for an amount equal to the FMV of the Class A shares of the capital stock of Holdco as at the date of Mr. ... The Trust will receive as consideration Note 2 issued by Newco for an amount equal to $XXXXXXXXXX, being the FMV of the Class G preferred shares of the capital stock of Holdco held at the date of transfer. ...

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