Search - consideration

The Purchase Agreement provided, among other things, that XXXXXXXXXX (or its designated subsidiaries) would acquire XXXXXXXXXX subsidiaries, including XXXXXXXXXX, and certain other assets from the XXXXXXXXXX (or from subsidiaries of the XXXXXXXXXX) for total cash consideration of US$XXXXXXXXXX (of which, subject to adjustments at closing, US$XXXXXXXXXX was attributable to the shares of XXXXXXXXXX), such consideration to be paid by XXXXXXXXXX to the XXXXXXXXXX at closing. 9. ...

This determination required the review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ... As a result, while the determination in any situation would involve a review of all relevant connecting factors and consideration as to how much weight should be given to each factor, the major determining factor is the source of the income. ...

In your letter you described a hypothetical situation for our consideration which has been restated as follows. ... For the purposes of the comments that follow it is assumed that none of these exclusions (i.e., transfers for FMV consideration, loans for value, or spouses living apart) are applicable in this case. ...

We replied that consideration should first be given (for reasons not repeated here) to the ability of the former spouse to have an RCA established by a holding company and also to the combined effects of paragraphs 56(1)(x) and (z) and subsection 70(2) of the Act as they may apply in such a situation. ... For example, it may be found that an amount is being transferred as consideration for a disposition of some property. ...

One of the tax considerations which may be relevant in considering the choice of trustee for a testamentary trust is the treatment of dividends received by a trust. ... We hope you find this information on possible tax considerations useful in your estate planning. ...

RPA disposera de la totalité des actions de Senco en faveur de Comco pour une considération de XXXXXXXXXX $. ... RPA utilisera le solde du produit de la vente des actions de Senco pour souscrire des actions du capital-actions des sociétés suivantes: Description des actions achetées Nombre Catégorie Considération XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 17. ...

The expected retained earnings balance for ACO at XXXXXXXXXX, after taking into consideration an $XXXXXXXXXX dividend to CCO in XXXXXXXXXX and $XXXXXXXXXX of estimated earnings to XXXXXXXXXX amounts to $XXXXXXXXXX. The expected retained earnings balance for DCO after taking into consideration $XXXXXXXXXX of estimated earnings to XXXXXXXXXX amounts to $XXXXXXXXXX. ...

The Shareholders propose to sell their shares of XXXXXXXXXX (the "XXXXXXXXXX Shares") to XXXXXXXXXX in consideration for the issuance by XXXXXXXXXX of common shares (the "XXXXXXXXXX Shares") having an aggregate fair market value equal to the fair market value of the XXXXXXXXXX Shares. ... The amount added to the stated capital, determined without reference to the Act, of the common shares of XXXXXXXXXX as a result of the issuance of the XXXXXXXXXX Shares received by the Shareholders as consideration for the transfer of the XXXXXXXXXX Shares will be limited, pursuant to subparagraph 26(3)(a)(ii) of the CBCA, to the paid-up capital of the XXXXXXXXXX Shares. 11. ...

In this regard, we refer you to the comments in paragraph 5 of Interpretation Bulletin IT-239R2, "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-Arm's Length Circumstances," a copy of which is enclosed. ... Rather, it appeared that you had settled your son's debt for no consideration. ...

These shares were originally issued for a total consideration of XXXXXXXXXX. ... These shares were originally issued for a consideration of XXXXXXXXXX. 6. ...