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Ruling

2017 Ruling 2016-0646891R3 - Pipeline and subsequent Split-up butterfly

“TC1 Redemption Note” means the non-interest bearing demand promissory note issued by TC1 to DC as consideration for the redemption by TC1 of the TC1 Butterfly Share held by DC. ... “TC2 Redemption Note” means the non-interest bearing demand promissory note issued by TC2 to DC as consideration for the redemption by TC2 of the TC2 Butterfly Share held by DC. ... As consideration for the redemption, TC1 will issue the TC1 Redemption Note, TC2 will issue the TC2 Redemption Note and TC3 will issue the TC3 Redemption Note. ...
Ruling

2016 Ruling 2016-0648991R3 - Internal spinoff reorganization of XXXXXXXXXX

As consideration for the shares, CanSub1 will issue the CanSub1 Note. ... As consideration for the shares, CanSub2 will issue the CanSub2 Note. ... As consideration for such interests, ForSub2 will pay an amount of cash equal to the aggregate FMV of such interests at the time of the transfer. 29. ...
Ruling

30 November 1997 Ruling 9722893 - XXXXXXXXXX BUTTERFLY (SPLIT-UP/GROSS-ASSET)

As sole consideration for such transfer, Newco 2 will issue to Child 2 an equal number of redeemable, retractable Class XXXXXXXXXX preferred shares having a fair market value and aggregate redemption amount equal to the fair market value of the Class XXXXXXXXXX preferred shares of Amalco transferred therefor. ... As sole consideration for such transfer, Newco 3 will issue to Child 3 an equal number of redeemable, retractable Class XXXXXXXXXX preferred shares having a fair market value and aggregate redemption amount equal to the fair market value of the Class XXXXXXXXXX preferred shares of Amalco transferred therefor. ... In consideration for such transfers, each of Newco 1, Newco 2 and Newco 3 will issue XXXXXXXXXX Class XXXXXXXXXX preferred shares and assume the Newco 1 Proportion, the Newco 2 Proportion or the Newco 3 Proportion, as the case may be, of the liabilities of Amalco. ...
Ruling

2024 Ruling 2024-1037241R3 - Double-wing butterfly

Sibling 1 Trust will transfer its XXXXXXXXXX DC Common Shares to TC1 in exchange for TC1 issuing XXXXXXXXXX TC1 Common Shares as sole consideration therefor having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX DC Common Shares transferred. 28. ... The agreed amount in respect of each eligible property so transferred will not be greater than the FMV of such property nor will it be less than the FMV, at the time of disposition, of the consideration therefor other than shares of the capital stock of TC1 or TC2, as the case may be, or a right to receive such shares. ... As consideration therefore, TC1 and TC2, as the case may be, will issue to DC the TC1 Redemption Note in respect of TC1’s share redemption and the TC2 Redemption Note in respect of TC2’s share redemption, each having a principal amount and FMV equal to the redemption amount of such TC’s Butterfly Shares. ...
Ruling

2014 Ruling 2013-0498651R3 - Single-Wing Split-up Butterfly

The bulk of DC's farm machinery and equipment was sold at auction in XXXXXXXXXX for cash consideration of $XXXXXXXXXX. ... Therefore, certain farm machinery and equipment was retained by DC and sold annually to the Partnership for cash consideration. ... As consideration therefor, TC will issue to DC Promissory Note1. DC will accept Promissory Note1 as full payment for the aggregate redemption amount of the TC Preferred Shares so redeemed. 27. ...
Ruling

2010 Ruling 2009-0306341R3 - Trusts as Shareholders on a Butterfly

Having regard to paragraph 84.1(1)(a), no amount will be added by either SiblingCo to the stated capital account maintained for any particular class of shares of its capital stock issued to a Trust in consideration of the transfer by the Trust of its DC shares. 14. In the event that shares of a SiblingCo are issued to a particular Trust in consideration for the transfer by it of DC shares in accordance with Subparagraph 13(b) above, the particular Trust will jointly elect with that SiblingCo, in prescribed form and within the time referred to in subsection 85(6), to have the rules in subsection 85(1) apply to such transfer. ... Where a marketable security to be transferred by DC to a SiblingCo has a FMV that is less than its ACB, the particular SiblingCo will not assume liabilities of DC in an amount greater than the FMV of the particular security as consideration for such marketable security and, for greater certainty, no election under subsection 85(1) will be made in respect of the transfer of such security. 21. ...
Ruling

2010 Ruling 2009-0325191R3 - Standard Split-up Butterfly

Grandmother will transfer her XXXXXXXXXX Class "C" and XXXXXXXXXX Class "D" Common Shares in the capital of DC to TC and in consideration therefore, TC will issue a number of Class "D" Preferred Shares having an aggregate redemption amount and FMV equal to the FMV of the Common Shares of DC transferred to TC. ... As consideration therefore, TC will issue a non-interest bearing demand promissory note (the "TC Note") having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class "E" Preferred Shares in the capital of TC redeemed. ... Nothing in this letter should be construed as confirmation, express or implied, that, for the purpose of any of the rulings given above, any adjustment to the FMV of the properties transferred or the redemption amount of the shares issued as consideration, whether pursuant to a price adjustment clause or otherwise, will be effective retroactively to the time of the transfer and issuance of shares. ...
Ruling

2007 Ruling 2006-0182221R3 - Reorganization of a mutual fund trust - s. 132.2

The Fund will subscribe for that number of XXXXXXXXXX Special Units as is equal to the number of its issued and outstanding Units in consideration for a cash payment estimated at $XXXXXXXXXX per XXXXXXXXXX Special Units. ... No consideration other than XXXXXXXXXX Special Units will be received by the Unitholders on the redemption of the Class A Shares and no consideration other than XXXXXXXXXX Ordinary units will be received by XXXXXXXXXX on the redemption of the Class B Shares. 35. ... No consideration other than Fund Special Units will be received by the Unitholders on the redemption of the XXXXXXXXXX Special Units and no consideration other than Units will be received by the Fund on the redemption of the XXXXXXXXXX Ordinary Units. 39. ...
Ruling

2007 Ruling 2007-0245711R3 - full split-up butterfly

In XXXXXXXXXX, DC's Aco shares were redeemed by Aco and a loan that DC owed to Aco was set-off by Aco as consideration for such redemption. ... As consideration therefor, Newco 1 will issue to Sibling 1 a number of Newco Class A Special Shares having an aggregate redemption amount and aggregate FMV equal to the aggregate FMV of the DC shares so transferred by Sibling 1 to Newco 1. ... As consideration therefor, Newco 2 will issue to Sibling 2 a number of Newco Class A Special Shares having an aggregate redemption amount and aggregate FMV equal to the aggregate FMV of the DC shares so transferred by Sibling 2 to Newco 2. ...
Ruling

2006 Ruling 2006-0182271R3 - Reorganization of a mutual fund trust - s. 132.2

Under the Fund DOT, the Fund is authorized to issue an unlimited number of Fund Rights in connection with or in relation to an issuance of securities that carry a right to convert or exchange into Fund Units for no additional consideration. ... The Fund will subscribe for one XXXXXXXXXX Common Share, the consideration for which will be $XXXXXXXXXX cash. 31. ... The Fund will subscribe for one MFC Common Share, the consideration for which will be a cash payment of $XXXXXXXXXX. 35. ...

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