Search - consideration

In regard to the issuance of shares, the stated capital account reflects (a) the par value of shares issued with a par value, (b) the amount ascribed by the directors for shares issued without par value or, in some jurisdictions, the fair market value of the consideration received for shares issued without par value, (c) a reduction for discounts granted (where permitted) for par value shares, and (d) a reduction for unpaid amounts (where permitted) for any issue. ... Canadian corporate law statutes generally provide that a corporation shall add the full amount of consideration it receives for any shares it issues to the appropriate stated capital account, 1 but shall not add an amount greater than the full amount of the consideration so received. 2 In addition, the corporate law statutes generally provide that a share shall not be issued until the consideration for the share is fully paid in money or in property or past services that are not less in value than the fair equivalent of money that the corporation would have received if the share had been issued for money. 3 Assuming that Opco is governed by similar corporate laws, Opco will not be permitted to issue the 30 Opco Shares to A unless the 30 Aco common shares to be received by Opco as consideration have a value of $300, being the fair equivalent of money that Opco could receive if it issued 30 Opco Shares for cash. ... This is because the 30 Opco Shares issued for $300 of cash consideration should have a fair market value of $300 immediately after their issuance as those 30 Opco Shares will in substance represent a 30/130 share in Opco's assets, which should have a fair market value of $1,300. ...

$XXXXXXXXXX consideration. XXXXXXXXXX. 12. On XXXXXXXXXX, Distributing incorporated Canholdco and subscribed for common shares for $XXXXXXXXXX consideration. 13. ... Parent will incorporate "Newco", a wholly-owned Canadian resident general purpose subsidiary corporation and subscribe for common shares for nominal consideration. Newco will then incorporate a wholly-owned Canadian resident general purpose subsidiary corporation, "Subnewco", and will subscribe for common shares for nominal consideration. 18. ...

Ces actions ont été émises pour une considération globale de XXXXXXXXXX $. 5. ... La Fiducie souscrira à XXXXXXXXXX actions de la catégorie « A » pour une considération globale de XXXXXXXXXX $, soit XXXXXXXXXX $ par action. ... Mme Y souscrira à XXXXXXXXXX actions de la catégorie « A » pour une considération globale de XXXXXXXXXX $, soit XXXXXXXXXX $ par action. ...

For the purpose of determining the specific country in which a particular business is carried on, different factors should be taken into consideration, including where the operations in substance or profit generating activities take place. ... Whether a particular apportionment of the consideration paid is reflective of the actual payments described in the exemption under subparagraph 212(1)(d)(vi) depends namely on the legal nature of what is being provided under the mixed contract, the legal relationships between the parties and the facts of the particular situation including the commercial reality of the parties and the consideration paid in these circumstances. In determining if the apportionment provided under the License Agreement is prima facie reflective of the obligation of the parties under subsection 212(1), consideration could be given, namely, to whether the parties had divergent interests in respect of the apportionment. ...

The initial Foreign Spinco XXXXXXXXXX was issued to Forco 3 in consideration for $XXXXXXXXXX USD. ... The initial Foreign Spinco Finco XXXXXXXXXX was issued to Foreign Spinco in consideration for $XXXXXXXXXX USD. ... Immediately following the DC ULC Transfer, Canco 1 (which is not a member of the DC ULC Group) will sell to TC ULC GP (which is not a member of the DC ULC Group) its: (a) XXXXXXXXXXCanGP 2 unit in consideration for $XXXXXXXXXX USD; (b) XXXXXXXXXX CanLP 7 unit in consideration for $XXXXXXXXXX USD; (c) XXXXXXXXXX CanLP 11 unit in consideration for $XXXXXXXXXX USD; (d) XXXXXXXXXX CanLP 12 unit in consideration for $XXXXXXXXXX USD; (e) XXXXXXXXXX CanLP 13 unit in consideration for $XXXXXXXXXX USD; (f) XXXXXXXXXX CanLP 14 units in consideration for $XXXXXXXXXX USD; (g) XXXXXXXXXX CanLP 15 unit in consideration for $XXXXXXXXXX USD; (h) XXXXXXXXXX CanLP 18 unit in consideration for $XXXXXXXXXXUSD; and (i) XXXXXXXXXX CanLP 19 unit in consideration for $XXXXXXXXXXUSD. ...

Your comments will be taken into consideration in deciding the issue. ...

Parnanzone Appeals and Referrals Division Tel. (613) 957-9232 Subject:  19(1)  Settlement Offer STALLED We are forwarding the ministerial correspondence file (yellow docket) for consideration and reply by your office since it involves a settlement offer for the taxpayer's outstanding appeal to the Tax Court of Canada. 24(1) As regards 19(1) remission request itself, it cannot be dealt with at this time because of the outstanding appeal.  ...

Your suggestion that the Government of Canada hold a lottery to assist with the national deficit has been forwarded to the Department of Finance their consideration. ...

Chisholm and the author we are returning herewith this file to your Division for consideration of the Notice of Objection submitted by the taxpayer. ...

Joy 957-2083 Assistance Division   F-3265 Income Tax Act French and English Versions Your enquiry of September 13 with regard to the different presentation of certain provisions of the Act, as between the French and English versions, was sent to the Tax Counsel Division, Department of Finance, for consideration. ...