Search - consideration

XXXXXXXXXX will issue XXXXXXXXXX shares to XXXXXXXXXX for FMV consideration. ... No non-share consideration will be received by XXXXXXXXXX on the exchange. ... XXXXXXXXXX will subscribe for common shares of Farm Holdco for FMV consideration. 64. ...

In consideration for the transfer, Holdco 1 will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value of the Shares at the time of the transfer. ... As consideration, XXXXXXXXXX will surrender its three notes receivable. 27.Each of Newlossco 1, Newlossco 2 and Newlossco 3 will select the date on which its taxation year will end. ... In consideration for the transfer, Holdco 2 will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value of the Shares at the time of the transfer. ...

The issue price of the Consideration Shares generally corresponded to the XXXXXXXXXX. 23. ... The consideration paid by Forco1 to Canco consisted entirely of the Consideration Shares. 25. ... In the year XXXXXXXXXX, Forco3 was transferred to Forco1 in exchange for XXXXXXXXXX Consideration Shares with an issue price of approximately US$XXXXXXXXXX; c. ...

As consideration, Opco will surrender the Newlossco1 Note and Newlossco2 Note. ... As consideration, Opco will surrender the Newlossco3 Note and Newlossco4 Note. ... As consideration, Opco will surrender the Newlossco5 Note and Newlossco6 Note. ...

I am also sending your comments about the clarity of the CRA's publications and frontline services to the responsible CRA officials for their review and consideration. ... Flaherty, Minister of Finance, for his consideration. I trust that the referrals are helpful. ...

., voluntary transfers of real or personal property without consideration) are not subject to tax in the hands of the recipients. ... However, the Canada Revenue Agency's general position is that recipients do not have to pay tax on most gifts and inheritances, also known as voluntary transfers of real or personal property without consideration. ...

To assist taxpayers, the CRA provides relief in extraordinary circumstances, such as after a natural disaster, by giving special consideration to taxpayers who have trouble meeting their tax obligations. ... Therefore, I am sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...

As a result, the second unenumerated paragraph of paragraph 32 of the Ruling is amended to read as follows: The addition to the stated capital under the BCA of the common shares issued by S Co as consideration for the shares transferred to it, as described above, will not exceed the aggregate paid-up capital of such transferred shares. The second unenumerated paragraph of paragraph 33 is amended to read as follows: The addition to the stated capital under the BCA to the common shares issued by F Co as consideration for the shares transferred to it, as described above, will not exceed the aggregate paid-up capital of such transferred shares. ...

Position: Confirmed that under the present law, the payment would not qualify and referred issue to Department of Finance for their consideration. ... I am therefore forwarding a copy of your letter to the Honourable Jim Flaherty, Minister of Finance, for his consideration. ...

Kuss Attention: XXXXXXXXXX October 25, 1994 Dear Sirs: Re: Subsection 85.1(4)- Technical Interpretation This is in reply to your letter dated May 26, 1994 regarding the application of subsection 85.1(4) to the following hypothetical situation. 1.Canco, a taxable Canadian corporation, owns 100% of USco, a foreign affiliate of Canco. 2.Prior to taking USco public, Canco transfers its shares in USco to a U.S. holding company (Holdco") for fair market value consideration consisting of Class A common shares of Holdco. Holdco is a foreign affiliate of Canco. 3.USco carries on an active business and all of its assets are "excluded property" as defined in subsection 95(1). 4.Holdco issues additional Class A common shares from treasury to the public for fair market value consideration. 5.Canco subsequently sells some of its shares of Holdco to the public. ...