Search - consideration

Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX, for cash consideration of $XXXXXXXXXX. Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX for cash, consideration of $XXXXXXXXXX. Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX, for cash consideration of $XXXXXXXXXX. 10. ...

The Offer was amended on XXXXXXXXXX so that the consideration payable for each BCO share tendered to the Offer is equal to XXXXXXXXXX. The Offer also provides that the maximum number of ACO Non-Voting Shares issuable pursuant to the offer is limited to XXXXXXXXXX% of the total consideration payable and the maximum amount of cash payable by ACO pursuant to the Offer is limited to XXXXXXXXXX% of the total consideration payable. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

Also at that time, the Series D and/or Series O Units held by Exchanging Unitholders in the Participating XXXXXXXXXX Public Fund will be cancelled for no consideration. ... As noted, it is not intended that this holding of units in XXXXXXXXXX will be retained; rather, as described below, New XXXXXXXXXX will dispose of this investment following completion of the foregoing proposed transactions. 1.3.9 Following the completion of the foregoing steps described above, on or shortly after the Effective Day, New XXXXXXXXXX and investors in the XXXXXXXXXX Group will dispose of their Units in XXXXXXXXXX in exchange for cash or in kind consideration. ... The Transferor will receive Units of the Transferee as the sole consideration for such property. ...

XXXXXXXXXX will each subscribe for 50% of the common shares of Newco with consideration equal to the nominal fair market value of those shares. 13. ... As sole consideration, XXXXXXXXXX will issue to each of XXXXXXXXXX Class B common shares and XXXXXXXXXX Class C preferred shares. ... In consideration Newco will issue to XXXXXXXXXX in full settlement a note in the amount of $XXXXXXXXXX with the same terms as the note issued by XXXXXXXXXX. 24. ...

As sole consideration for the transfer, DC will increase Holdco's membership interest in DC by an amount that will be equal to the fair market value of the FAcos' shares transferred by Holdco to DC. ... As sole consideration for the transfer, DC will increase Newco's membership interest in DC by an amount that will be equal to the fair market value of the FAcos' shares transferred by Newco to DC. ... The cancellation of the shares in the capital of BV on the Conversion in exchange for the issuance of the membership interests in DC will occur on a tax-deferred basis for the purposes of the Act, pursuant to subsection 86(1), such that: (i) the cost to Holdco of the shares of DC receivable as consideration for the cancellation of the BV shares will be deemed to be equal to Holdco's adjusted cost base of its shares of BV immediately before the Conversion; (ii) Holdco shall be deemed to have disposed of the BV shares for proceeds of disposition equal to the cost of the DC shares receivable by Holdco referred to in C(i) above; (iii) the cost to Newco of the shares of DC receivable as consideration for the cancellation of the BV shares will be deemed to be equal to Newco's adjusted cost base of its shares of BV immediately before the Conversion; and (iv) Newco shall be deemed to have disposed of the BV shares for proceeds of disposition equal to the cost of the DC shares receivable by Newco referred to in C(iii) above. ...

On XXXXXXXXXX, CanCo transferred its interest in ForeignCo to Can-FHoldCo and received, as consideration, additional shares of Can-FHoldCo. ... On XXXXXXXXXX, Foreign Parent transferred its XXXXXXXXXX% interest in CanCo to Newco and received, as consideration, additional shares of Newco. 19. ... As consideration, CLP will pay LuxFinCo an amount of C$XXXXXXXXXX cash and will issue notes payable to LuxFinCo for the balance (the "CLP Notes"). ...

As sole consideration for such transfer, XXXXXXXXXX. The transfer will occur on a tax-deferred basis pursuant to subsection 85(1). ... As consideration for such contribution, XXXXXXXXXX will issue XXXXXXXXXX, having an aggregate FMV equal to $XXXXXXXXXX. ... As consideration for such transfer, XXXXXXXXXX will pay XXXXXXXXXX to XXXXXXXXXX. ...

" The courts have taken the view that, for the purpose of computing income to the taxpayer, the value of what is received has to be taken into consideration even though it is neither realized nor realizable. ... Under these circumstances, it is reasonable to conclude, in the absence of evidence to the contrary, that the taxpayer is receiving consideration which is worth the fair market value of the asset transferred. Generally speaking, when beneficial ownership of a property is transferred from a taxpayer to another party in exchange for consideration, the profit on a sale should be recognized at the time of the disposition. ...

The consideration paid by the borrower is in the form of a right provided to the lender to reacquire an equal number of identical securities for no consideration other than the extinguishment of the right. ... While a question of fact, it is arguable that the value of this consideration is equal to the fair market value at the time the shares are acquired. ... (That is, the borrower will purchase from a third party the number of securities it originally borrowed and dispose of them to the lender in consideration for the settlement of its obligation under the right. ...

All of the shares of TC2 held by DC were redeemed in consideration of the issue of a promissory note by TC2 to DC. ... No amount was paid in consideration of the non-compete. Proposed Transactions 19. ... No other consideration will be received by TC1 on the share exchange. ...