Search - consideration

As sole consideration for these transfers, Wind-upco1 will issue to Parentco common shares of its capital stock. 22. ... As consideration, Parentco will surrender the Newlossco1 Note, Newlossco2 Note and Newlossco3 Note. ... As consideration, Parentco will surrender the Newlossco4 Note and Newlossco5 Note. ...

On XXXXXXXXXX, Parent transferred its XXXXXXXXXX to Holding LP in consideration for Holding LP Units. 15. ... Sisterco will sell all of the shares of GPco Holding to New Parent for nominal consideration. ... Similarly, Sisterco will sell all of the shares of GPco Master to New Parent for nominal consideration. ...

For greater certainty, the consideration received by Holdco B from Childco 2 will have an aggregate FMV equal to the FMV of the partnership interest in Farm Partnership so transferred. ... For greater certainty, the consideration received by Holdco A from Childco 1 will have an aggregate FMV equal to the FMV of the partnership interest in Farm Partnership so transferred. ... For greater certainty, the consideration received by Farmco 2 from Childco 3 will have an aggregate FMV equal to the FMV of the partnership interest in Farm Partnership so transferred. ...

Father will receive no consideration from Daughter on the transfer. 5. ... As consideration, Father will receive a partnership interest in FarmPart. ... As consideration, Son will receive a partnership interest in FarmPart. ...

The aggregate in-the-money value based on the Cash Consideration was approximately $XXXXXXXXXX (including Target Options held by both residents and non-residents of Canada). 6. ... On XXXXXXXXXX, the increased consideration, referred to in 11 above, was discussed at a Target directors' meeting. ... Corp at a cash offer price of $XXXXXXXXXX (the "Cash Consideration"). ...

Both XXXXXXXXXX and XXXXXXXXXX agreed that XXXXXXXXXX's issuance of XXXXXXXXXX and XXXXXXXXXX common shares to XXXXXXXXXX in consideration for the XXXXXXXXXX Note and the XXXXXXXXXX Note would satisfy in full its obligations under such debt obligations 19. ... In consideration for the XXXXXXXXXX FPA and the XXXXXXXXXX FPA, XXXXXXXXXX issued XXXXXXXXXX common shares to XXXXXXXXXX having a paid-up capital ("PUC") and a purported FMV equal to C$XXXXXXXXXX. 22. ... In a letter dated XXXXXXXXXX, the Representative enclosed revised PUC calculations for XXXXXXXXXX as of XXXXXXXXXX which reflected a XXXXXXXXXX value for the PUC of the common shares issued in consideration for the XXXXXXXXXX FPA and the XXXXXXXXXX FPA. ...

Paragraph 29 of the Ruling is also amended to delete the second sentence and to substitute the following: As consideration therefor, Sibling 3 Co will issue XXXXXXXXXX Special A Shares to Sibling 3. Paragraph 30 of the Ruling is also amended to delete the second sentence and to substitute the following: As consideration therefor, Sibling 1 Co will issue XXXXXXXXXX Special A Shares to Sibling 1. ... Paragraph 36 of the Ruling is amended to delete the second sentence and to substitute the following: As consideration therefor, TG II will issue XXXXXXXXXX Special C Shares to DE. ...

Accordingly, the Fee is not a payment made by the borrower in respect of borrowed money as consideration for a reduction in the rate of interest payable for purposes of subsection 18(9.1). ... Paragraph 18(9.1)(c) Paragraph 18(9.1)(c) refers to payments made as consideration for a reduction in the rate of interest payable by the taxpayer on the debt obligation. ... Accordingly, the Fee is not, in our view, a payment made by B Co in respect of borrowed money as consideration for a reduction in the rate of interest payable. ...

Principal Issues: Cost of shares acquired as a result of a foreign merger Position: Cost of shares includes an amount equal to the fair market value of the consideration given to acquire such shares. ... (i) At the Effective Time, Mergeco will issue common shares (the "New Mergeco Shares") to Holdco in consideration for Holdco issuing the Holdco Note and the New Holdco Shares to Canco (as described in paragraph 10(h) above). ... (k) Canco will add to the stated capital account of the Canco common shares issued to the former Targetco shareholders an amount equal to the Holdco Consideration Amount (which equals the Mergeco Consideration Amount) less any amounts paid by Canco to such shareholders in lieu of the issuance of fractional shares. ...

Trust B1 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco B and, as consideration therefor, Holdco B will issue to Trust B1 a number of its Class C Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust B1. ... Trust B2 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco B and, as consideration therefor, Holdco B will issue to Trust B2 a number of its Class D Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust B2. ... Trust S1 will transfer: (a) all of its Class XXXXXXXXXX Shares of DC to Holdco S and, as consideration therefor, Holdco S will issue to Trust S1 a number of its Class B Preference Shares having an aggregate FMV equal to the aggregate FMV, at that time, of the Class XXXXXXXXXX Shares of DC transferred to it by Trust S1. ...