Search - consideration

This specified amount would not exceed the fair market value of the consideration for which the share was issued. ... That is, will the Department accept the fair market value of the consideration as the specified amount by default? ... The specified amount does not exceed the fair market value of the consideration for which the share was issued. 3. ...

XXXXXXXXXX DC XXXXXXXXXX transferring its shares of XXXXXXXXXX to XXXXXXXXXX in exchange for cash consideration of $XXXXXXXXXX and XXXXXXXXXX common shares of XXXXXXXXXX. ... On XXXXXXXXXX, DC reduced the stated capital of its common shares by $XXXXXXXXXX and paid cash of $XXXXXXXXXX to Family Trust as consideration for this stated capital reduction. ... As sole consideration, TC1 will issue XXXXXXXXXX Class A preferred shares having a fair market value equal to the fair market value at that time of the XXXXXXXXXX Class A special shares of DC. ...

Ltd will issue new common shares for cash consideration equal to their FMV. ... XXXXXXXXXX will purchase Ltd Class B shares from XXXXXXXXXX equally for consideration equal to their FMV. XXXXXXXXXX will give demand promissory notes as consideration for the shares. ...

"Eligible capital property" ("ecp") is defined in subsection 54(d) to mean "any property, a part of the consideration for the disposition of which would, if he disposed of the property, be an eligible capital amount in respect of a business". ... Subparagraph 14(5)(a)(iv) reads "the aggregate of all amounts each of which is 3/4 of the amount, if any, by which (A) an amount which, as a result of a disposition occurring after the taxpayer's adjustment time and before that time, he has or may become entitled to receive, in respect of the business carried on by or formerly carried on by him where the consideration given by him therefor was such that, if any payment had been made by him after 1971 for that consideration, the payment would have been an eligible capital expenditure of the taxpayer in respect of the business exceeds (B) all outlays and expenses to the extent that they were not otherwise deductible in computing the taxpayer's income and were made or incurred by him for the purpose of giving that consideration". ... Justice Thurlow had occasion to consider the term transaction and concluded that the word was "wide enough to embrace all types of voluntary processes or acts by which property of one person may become vested in another without regard for the reason for such processes or acts and regardless also of whether the process is undertaken or the act is done for consideration in whole or in part or for no consideration at all. ...

In circumstances where a couple jointly purchases property which they register in both their names but the purchase funds including principal and interest payments on any loan obligation are provided solely from the assets or earnings of only one of the spouses (the "Contributing Spouse") it is our view that the attribution rules would apply to property transferred by the Contributing Spouse to the other spouse as consideration for the other spouse's share of the jointly held property. ... In particular, you describe a situation where a taxpayer transfers for valuable consideration, using legally effective steps, including having the title for the property changed, his or her share of the principal residence to the taxpayer's spouse (the "Spouse"). ... Except where fair market value consideration is paid by the spouse or the parties are living separate and apart by reason of a breakdown of their marriage, income earned and capital gains and losses realized on property transferred or loaned from a taxpayer to the taxpayer's spouse (and on property substituted for that property) are generally deemed to be the income, gains or losses of the taxpayer and not of the taxpayer's spouse (the "Attribution Rules"). ...

Where 100% of the shares of a corporation are donated to a private foundation for no consideration, will the foundation be subject to revocation of its charitable registration pursuant to paragraph 149.1(4)(c) of the Act? ... Paragraph 149.1(4)(c) will not apply provided not more than 5% of the shares of the corporation have been acquired by the foundation for consideration. 3. ... This deeming rule will apply only where the foundation has not purchased or otherwise acquired for consideration more than 5% of the issued shares of any class of the corporation. ...

As sole consideration therefor, Father will receive from Holdco 1, common shares with a par value of $XXXXXXXXXX per share. ... The share conditions of the special preferred shares will contain a price adjustment clause to ensure that their value is equal to the value of the assets received as consideration for their issue. ... Holdco 3 will reduce the aggregate paid-up capital of the XXXXXXXXXX% preferred shares of Holdco 3 issued to Father by an aggregate amount of $XXXXXXXXXX or $XXXXXXXXXX per share without the payment of any consideration whatsoever pursuant to the Companies Act. ...

/ Est-ce que les avantages imposables doivent être pris en considération aux fins du test d'au moins 14 jours consécutifs sans rémunération dans la définition d'un employé admissible et si oui, comment déterminer la période visée par un tel avantage? ... 3- Is there a difference between the remuneration that has to be taken in consideration for the 14 day remuneration condition for an individual to qualify as an “eligible employee” and the “eligible remuneration” paid to an employee to calculate the CEWS? ... Position: 1- Yes / Oui 2- No / Non 3- Yes / Oui Reasons: 1- Taxable benefits are remuneration and therefore, an employer must take these benefits into consideration for purposes of determining whether the 14 day remuneration condition is met. ...

Also on XXXXXXXXXX, CanSub3 transferred the Yco Shares to Target in consideration for the Yco Note. ... Buyer XXXXXXXXXX loaned $XXXXXXXXXX to BidAmalco in consideration of the BidAmalco Acquisition Note. ... BidAmalco loaned cash to Target in consideration of the BidAmalco Downstream Note. 74. ...

The amount that will be added to the stated capital account of the Class XXXXXXXXXX Preference Shares of a Holdco upon the issue of Class XXXXXXXXXX Preference Shares by such Holdco to XXXXXXXXXX in consideration for assets for which no election will be made pursuant to subsection 85(1), will be equal to the full amount of the consideration received for such Class XXXXXXXXXX Preference shares less the amounts of liabilities of XXXXXXXXXX assumed by such Holdco as consideration for such assets. ... The consideration to be paid by XXXXXXXXXX Holdco for such acquisition will be cash and debt (not convertible into any other property) equal to the negotiated price. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...