Search - consideration

The Class D Shares were issued for cash consideration of $XXXXXXXXXX. ... The Class G Shares were issued on XXXXXXXXXX as consideration for the transfer, by each of F1-TC1, F1-TC2, F2-TC1, F3-TC1 and F4-TC1 (collectively referred to as the "Five Holdcos"), of the shares of XXXXXXXXXX. ... One or more common shares of Newco will be issued to F3-Individual1 on incorporation for nominal consideration. 18. ...

The amount of any deferred income tax will not be taken into consideration for this purpose because such amount does not represent a legal obligation of the particular corporation. ... As consideration for the transfer of the Transferred Assets to Newco, Newco will issue Newco Special Preferred Shares to DC. ... The consideration to be paid by DC to SubE for this interest in P3 will be the issuance of a demand promissory note (the "Second DC Note") with the principal amount being equal to the foregoing purchase amount. ...

For greater certainty, no liabilities of DC2 will be assumed by either of Subco1 or Subco2 as consideration for the transfer. ... For greater certainty, other than as described in (e) above, no liabilities of DC1 will be assumed by Tempco1 as consideration for the property transfers described herein. ... For greater certainty, other than as described in (e) above, no liabilities of DC1 will be assumed by Tempco2 as consideration for the property transfers described herein. ...

As part of the consideration for the transfer of the property, DC issued to Individual B: (a) XXXXXXXXXX DC Class A Common Shares having an aggregate FMV and PUC of $XXXXXXXXXX; and (b) XXXXXXXXXX DC Class B Preferred Shares having an aggregate FMV, redemption amounts and PUC of $XXXXXXXXXX. ... As the sole consideration, Newco will issue to each of Individual A and the Trust Newco Class C Preferred Shares having an aggregate FMV, redemption and retraction amount equal to the FMV at that time of the DC shares that each of Individual A and the Trust transferred to Newco. ... As the sole consideration, DC will issue to (a) each of Individual A and Child1, DC Class C Preferred Shares having an aggregate FMV and redemption and retraction amount equal to the FMV at that time of the property of Individual A and Child1 transferred to DC, as the case may be, as described herein, and (b) Child3, DC Class D Preferred Shares having an aggregate FMV and redemption and retraction amount equal to the FMV at that time of the property of Child3 transferred to DC as described herein. ...

Following the incorporation of the XXXXXXXXXX NROs, XXXXXXXXXX subscribed for and has become the owner of XXXXXXXXXX Class B Shares of each NRO in consideration of a cash payment of $XXXXXXXXXX per share for a total investment of $XXXXXXXXXX per NRO. ... In addition, XXXXXXXXXX and a resident of the United States, subscribed for and became the owner of XXXXXXXXXX Class A Shares of each NRO in consideration of a cash payment of $XXXXXXXXXX per share for a total investment of $XXXXXXXXXX per NRO. ... In return, XXXXXXXXXX or the purchaser of that part of the Property will pay to the NRO the relevant portion of the sale proceeds or purchase price respectively from that part of the Property as consideration for the surrender, which will be considered a disposition of an interest in the Royalty. ...

(d) DC redeemed the DC Preferred Shares and issued promissory notes to Holdco as consideration for the redemptions. ... (b) DC transferred marketable securities to Subco and in consideration therefor Subco issued XXXXXXXXXX common shares to DC. ... In XXXXXXXXXX, DC transferred marketable securities to Subco and in consideration therefor Subco issued XXXXXXXXXX common shares to DC. ...

Each Class F share is redeemable and retractable for the consideration for which each such share has been issued (the redemption amount). ... As consideration therefore, TC1 Sub will issue to DC the TC1 Sub Redemption Note having a principal amount and FMV equal to the aggregate redemption amount and FMV of the TC1 Sub Preferred Shares so redeemed by it. ... As consideration therefore, DC will issue to TC1 the DC Purchase Note having a principal amount and FMV equal to the aggregate FMV of such shares so purchased for cancellation. ...

In consideration for the grant of such rights, the Resident agrees to pay the Non-Resident the greater of an amount equal to a percentage of amounts invoiced to customers from sales of the product and a pre-determined fixed minimum amount. ... The payments in question are clearly in consideration for obtaining the rights to manufacture and sell the product and are based on a share of the profits that the Resident will realize from using such rights. ...

Danilack notes, it is easy to do so by simply "invoking a different comparable set, applying a different methodology, or pointing to extraneous factual considerations." ... I put forward this proposition because, as we all know, it's relatively easy to challenge any transfer price or expense allocation simply by invoking a different comparable set, applying a different methodology, or pointing to extraneous factual considerations. ...

Corporation B wants to acquire some of the common shares of its capital stock owned by Corporation A for a consideration less than their fair market value (FMV), and Corporation A wants to sell these common shares to Corporation B for the same consideration. ...