Search - consideration

On or before XXXXXXXXXX, and immediately before the transactions described below, US Subco will purchase the following assets from various members of Group A at their FMV and issue the following FMV consideration: i) shares of USco 7 from USco 3 for sole consideration consisting of US$XXXXXXXXXX in cash; ii) the Group A-1 Assets from USco 13 for sole consideration consisting of XXXXXXXXXX newly issued common shares of US Subco with a FMV of US$XXXXXXXXXX; and iii) the Group A-2 Assets from USco 18 for consideration consisting of XXXXXXXXXX newly issued common shares of US Subco with a FMV of US$XXXXXXXXXX, US$XXXXXXXXXX in cash and US$XXXXXXXXXX newly issued non-voting preferred shares of US Subco with a FMV of US$XXXXXXXXXX As a result of the above, the aggregate purchase price for the above assets acquired by US Subco will be equal to their aggregate FMV of US$XXXXXXXXXX and the aggregate FMV consideration to be paid by US Subco in respect of these assets will consist of US$XXXXXXXXXX of common shares of US Subco, US$XXXXXXXXXX of non-voting preferred shares of US Subco and cash of US$XXXXXXXXXX. 13. Newco US will then purchase all the issued and outstanding common shares of US Subco for their FMV in exchange for cash and/or common shares of Newco US that have a FMV equal to the US Subco shares so acquired by Newco US as follows: i) USco 13 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of XXXXXXXXXX newly issued common shares of Newco US with a FMV of US$XXXXXXXXXX; ii) USco 18 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of XXXXXXXXXX newly issued common shares of Newco US with a FMV of US$XXXXXXXXXX; and iii) USco 4 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of US$XXXXXXXXXX in cash. ... As sole consideration therefor, Pubco will issue notes payable with an aggregate principal amount and FMV of US$XXXXXXXXXX (the "Pubco Notes"). ...

On XXXXXXXXXX, Profitco subscribed for an additional XXXXXXXXXX common shares of Lossco for consideration of $XXXXXXXXXX and, during XXXXXXXXXX, Profitco subscribed for an additional XXXXXXXXXX common shares of Lossco for consideration of $XXXXXXXXXX. ... Forco 2 will acquire all the shares of Lossco held by Forco 3 for fair market value consideration. ... Newco will then redeem the Class B shares issued to Lossco as described in paragraph 17 above for cash consideration equal to their fair market value. 19. ...

Position: To the extent the fee represents consideration for items described within subparagraphs 212(1)(d)(i),(ii) and (iv), and does not represent consideration for copyright in subparagraph 212(1)(d)(vi) the fee will, subject to the U.S Treaty, be subject to withholding. ... Our Comments At the outset, we believe the application of paragraph 212(1)(d) of the Act in these circumstances depends on whether the PLF is characterized as consideration for the Procurement Rights or as additional consideration for the Franchise Rights. ... In our view, those obligations are consideration for the grant and the continued use of the Franchise Rights. ...

The CANCO4 Shares are all owned by CANCO1, having been purchased from an arm's length party on XXXXXXXXXX for a cash consideration of $XXXXXXXXXX. ... Each asset which comprises the division will be transferred in exchange for consideration equal to its fair market value. b. ... A will transfer the CANCO1 Subsidiary shares to SUBHOLDCO3 for consideration consisting of preference shares of the capital stock of SUBHOLDCO3 with a fair market value and a redemption amount equal to the fair market value of the CANCO1 Subsidiary shares. a. ...

8 December 1981 Income Tax Severed Letter RCT 85-075 F Unedited CRA Tags 85 RE:     Your memo of October 23, 1981 It is our opinion that in the situation which you described in your above-noted memorandum, the preference shares taken back as part of the consideration under a section 85 rollover would not be considered to be non-share consideration for the purpose of determining the transferor's proceeds of disposition. ...

We are satisfied that the employer request for extension warrants consideration and we are prepared to recommend acceptance. Your favourable consideration of this matter is requested. Yours sincerely, C. ...

For greater certainty, no non-share consideration will be paid by A Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by B Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by C Holdco in respect of the transfer of the shares so acquired by it. ...

On incorporation, Real Co subscribed for at least one Common Share of each of the Real-Subcos for nominal consideration. ... On incorporation, TC3 subscribed for at least one Common Share of each of the TC3-Subcos for nominal consideration. ... Real Co will transfer to TC3 all of its Common Shares of each of the Real-Subcos in consideration for Common Shares of TC3. 23. ...

Management received the Rollover Consideration and the other Holders received cash. ... Parent subscribed for common shares of Shareholder 5 in consideration for $XXXXXXXXXX. 9(L). ... Bidco subscribed for common shares of Buyerco in consideration for approximately $XXXXXXXXXX. 10. ...

Subsection 168(1) required the company to pay the GST on the earlier of the day that the consideration for the supply was paid, and the day that the consideration for the supply becomes due. Subsection 152(1) deems consideration for a taxable supply to become due on the earliest of three events. In the instant case, the provisions of paragraph 152(1)(a) apply to the extent of the earlier of the day that the supplier first issued an invoice in respect of the supply for that consideration or part and the date of that invoice. ...