Search - consideration
Results 3141 - 3150 of 8026 for consideration
Ruling
2096 Ruling 9600283 - BUTTERFLY REORGANIZATION
As sole consideration for such transfer, Newco will issue to the respective transferor Newco Preferred Shares that are redeemable and retractable in the aggregate at an amount equal to the fair market value of the Reorganization Shares transferred to Newco. ... In consideration for such transfer, Newco will issue to XXXXXXXXXX Newco Reorganization Shares with an aggregate redemption amount ("Newco Redemption Amount") equal to the aggregate net fair market value of the transferred property. ... As sole consideration for such transfer, Newco will issue to the respective transferor Newco Common Shares on XXXXXXXXXX basis. ...
Ruling
2001 Ruling 2001-0072903 - Butterfly
The authorized capital of each of Newco1 and Newco2 will consist of the following shares: (a) an unlimited number of common shares; and (b) an unlimited number of XXXXXXXXXX shares (the "Newco XXXXXXXXXX Shares") which will be first issued to DC as consideration for the transfers of property as described in paragraph 20 below. ... The fair market value, redemption and retraction price of each Property Transferee’s XXXXXXXXXX shares will be equal to the net fair market value of the consideration for which they are issued. ... DC will issue to each of Transferee1 and Transferee2, as consideration for the purchase of the DC shares owned by Transferee1 and Transferee2, two non-interest bearing promissory notes (hereinafter referred to as the “DC Notes” and individually as the “DC Note”). ...
Ruling
2001 Ruling 2001-0077213 - Split- Up Butterfly
As sole consideration for such transfer, Bco will issue to Daughter 1 XXXXXXXXXX common shares. ... As sole consideration for such transfer, Cco will issue to Daughter 2 XXXXXXXXXX common shares. ... In consideration, the Subcos will each issue a non-interest-bearing demand promissory note to Aco (the "BcoSub Note" and the "CcoSub Note", respectively) with a principal amount, stated by formula, equal to the purchase price of the shares so purchased for cancellation. 26. ...
Ruling
2002 Ruling 2002-0124893 - Split up Butterfly
In consideration, DC will issue to TC1 a non-interest-bearing demand promissory note (the "DC1 Note") with a principal amount and FMV equal to the aggregate FMV of the shares so purchased and redeemed. ... In consideration, DC will issue to TC2 a non-interest-bearing demand promissory note (the "DC2 Note") with a principal amount and FMV equal to the aggregate FMV of the shares so purchased and redeemed. ... For greater certainty, subsection 85(2.1) will not apply to reduce the PUC of the common shares of TC1, TC2, TC3 and TC4 issued as consideration for the DC shares so acquired. ...
Ruling
1999 Ruling 9903153 - BUTTERFLY REORGANIZATION
This investment has a nominal fair market value and will be disposed of for fair market value cash consideration (to a person other than Opco or any corporation controlled by Mr. ... No other consideration will be paid by Newco for such shares. The addition to the stated capital of the Newco common shares in respect of each such transfer will be equal to the FMV of the common shares of Propertyco that were transferred. ... The amount to be added to the stated capital of the Newco preference shares to be issued as described herein will be equal to the FMV of the consideration for which they were issued. ...
Ruling
2020 Ruling 2019-0818261R3 - Split-Up Farm Butterfly
As sole consideration for such transfers, TC1 will issue a number of Class B Special Shares to Mr. ... As consideration therefore, TC1 will issue to DC a non-interest bearing demand promissory note (the “TC1 Redemption Note”) having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class A Special Shares so redeemed by it. ... As consideration therefore, DC will issue to TC1 a non-interest bearing demand promissory note (the “DC Redemption Note”) having a principal amount and FMV equal to the aggregate FMV and/or aggregate redemption amount, as applicable, of such shares so purchased for cancellation or redeemed. ...
Ruling
2009 Ruling 2008-0304371R3 - Single-Wing Butterfly
A Sub Holdco and B Sub Holdco each acquired their Opco Common Shares from its parent company, A Holdco and B Holdco, respectively, on XXXXXXXXXX for share consideration consisting of XXXXXXXXXX common shares issued from their respective treasury stocks. ... On its incorporation, B Sub Holdco subscribed for common shares of B NomineeCo for nominal consideration. 54. ... B Sub Holdco will be authorized to issue an unlimited number of the B Sub Holdco Special Shares each of which will be voting, redeemable and retractable at an amount (the "B Sub Holdco Special Share Redemption Amount") equal to the result obtained when the aggregate fair market value of the property transferred to B Sub Holdco on the date of issuance as consideration for the B Sub Holdco Special Shares less the aggregate amount of the non-share consideration, if any, paid, assumed or delivered by B Sub Holdco for the acquisition of such property is divided by the number of B Sub Holdco Special Shares issued as consideration therefor. 57. ...
Ruling
2012 Ruling 2011-0403291R3 - Treaty exempt sale
Sellco1 transferred all of the issued and outstanding common shares of Canco to Foreignco3 in consideration for $XXXXXXXXXX. 33. ... Sellco2 conveyed ABC Assets to Keepco1 in consideration for XXXXXXXXXX common shares of Keepco1. ... Keepptp1 was dissolved and Sellco1 will assume for nominal consideration all of Keepptp1's rights and obligations. 64. ...
Ruling
2013 Ruling 2012-0443081R3 - Distribution of pre-72 Capital Surplus on Hand
More specifically, XXXXXXXXXX Class B shares of BCo were acquired from Father 1-2 in consideration for XXXXXXXXXX Class E shares of ACo and XXXXXXXXXX Class B shares of BCo were acquired from Father 3-4 in consideration for XXXXXXXXXX Class E shares of ACo. ... The Class Z.2 preferred shares will be redeemable and retractable for the fair market value of the consideration for which they were issued. ... ACo will transfer its BCo Shares to Newco and will receive as consideration Class 4 preferred shares of Newco having an aggregate redemption value equal to the fair market value of the transferred BCo Shares. ...
Ruling
2009 Ruling 2007-0256411R3 - Public butterfly
Each non-voting second preference share was issued for consideration, the FMV of which was equal to the cost of the share to the original owner at the time of its issuance. The PUC of the class of non-voting second preference shares is equal to the FMV of the consideration for which the outstanding shares were issued. ... The amount to be specified will not exceed the FMV of the consideration for which the share is issued. ...