Search - consideration

The terms and conditions of the ACo Class F Special Shares do not entitle the holder to vote except as otherwise provided under Act1 and each share is redeemable and retractable at a price equal to the FMV of the consideration paid to acquire such share on issuance. ... The terms and conditions of the Newco Class A Preferred Shares do not entitle the holder to vote, and each share is redeemable and retractable at a price equal to the FMV of the consideration paid to acquire such share on issuance. ... The Estate will transfer its ACo Shares to Newco, and in exchange the Estate will receive the following consideration from Newco: a. ...

As sole consideration for such transfer, TransfereeCo will issue to Mr. ... For greater certainty, the agreed amount for any eligible property included in the subsection 85(1) elections referred to herein will not exceed the fair market value of such property and will not be less than the amount of any liabilities assumed by TransfereeCo as consideration for the transfer of such property. The amount that will be added to the stated capital of the TransfereeCo Preferred Shares which are to be issued as consideration for the property of XXXXXXXXXX which will be transferred to TransfereeCo as described in paragraph 12 above will be equal to the amount by which the aggregate cost of the property to TransfereeCo (determined pursuant to subsection 85(1) of the Act where relevant) exceeds the amount of liabilities assumed by TransfereeCo as consideration therefor. 14. ...

To the best of your knowledge and that of XXXXXXXXXX, none of the issues in respect of which rulings are herein requested is currently under consideration by a tax services office or taxation centre in connection with a tax return or notice of objection already filed. ... XXXXXXXXXX will subscribe for a nominal amount of common shares of Newco A for a nominal cash consideration. 23. ... Newco A will subscribe for a nominal amount of common shares of each Lender Newco for a nominal cash consideration. ...

Class C preferred shares that carry one vote per share, are redeemable but not retractable and have a redemption amount equal to the FMV of the consideration received; d. ... Class E preferred shares that carry one vote per share, are redeemable and retractable and have a redemption amount equal to the FMV of the consideration received; and f. Class F and G preferred shares that do not carry voting rights, are redeemable and retractable and have a redemption amount equal to the FMV of the consideration received. ...

Part B – Transfer of a Policy to a Corporation and Subsequent Gift to a Charity On March 1, 2021, Individual A transferred the recently acquired Policy to a wholly owned corporation (Opco) for no consideration. ... Spouse A transfers the Policy to Spouse B for no consideration. At the time of the transfer of the Policy, the Policy's ACB was $20,000, CSV was $60,000 and FMV was $70,000. ... Spouse A transfers the Policy to Spouse B for no consideration. At the time of the transfer of the Policy, the Policy’s ACB is $10,000, CSV is $20,000 and FMV is $22,000. ...

DC will make payments to Holdco A Sub in consideration for Holdco A Sub assuming undertakings of DC to which paragraph 12(1)(a) applies. ... In consideration of such redemption, Holdco A Sub will issue to DC a demand note in an amount equal to the aggregate Holdco A Sub Special Shares Redemption Amount of the shares so redeemed. ... For greater certainty, the provisions of paragraph 85(1)(b) will not be applicable in respect of the transfer of a particular property where the portion of the XXXXXXXXXX or other liability of DC that relates to that particular property, that exceeds the agreed amount with respect to the particular property, is not assumed by Holdco A Sub as consideration for the transfer of that particular property but is assumed by Holdco A Sub as consideration for the transfer of another property as described in Paragraph 32. ...

The Newco Special Share shall be redeemable and retractable for an amount equal to the fair market value of the consideration received by Newco upon the issuance of such share (the "Newco Special Share Redemption Amount"). ... In order to have New Subco approve the proposed transactions described below, upon organization one (1) New Subco Common Share will be issued by New Subco to Canco for cash consideration of $XXXXXXXXXX. ... The provisions of subsection 85(2.1) will not apply to reduce the PUC of the Newco Special Share to be issued to Canco by Newco as consideration for the Butterfly Transfer of property to Newco, as described in paragraph 30 above. ...

The aggregate FMV of the consideration issued by AcquisitionCo to Pubco for such transferred property will equal the FMV thereof. ... The aggregate FMV of the consideration issued by AcquisitionCo for the PubcoSub Indebtedness will equal the FMV thereof. ... The addition to the stated capital of the New Target Amalco Preferred Shares that will be issued as consideration for the PubcoSub Indebtedness under the CBCA will be equal to the FMV (i.e. the principal amount plus any accrued interest) of the PubcoSub Indebtedness. ...

Upon incorporation, Newco will issue 1 Common Share to each of the Partners, including the Named Partners, for nominal consideration. ... As sole consideration for the Partnership's transfer to Newco of the Non-85(2) Property, Newco will assume a portion of the Liabilities equal in amount to the fair market value of Non-85(2) Property. ... Immediately prior to the winding up, the Partnership will have no property other than the consideration it received from Newco in respect of the disposition of the 85(2) Property to Newco. ...

Consideration for the transfer of the XXXXXXXXXX common shares of the capital stock of DC will consist of XXXXXXXXXX Class A common shares of the capital stock of TC with a FMV equal to the FMV of the XXXXXXXXXX common shares of the capital stock of DC transferred. ... Consideration for the transfer of the XXXXXXXXXX preferred shares of the capital stock of DC will consist of XXXXXXXXXX Class A preferred shares of the capital stock of TC with a FMV equal to the FMV of the XXXXXXXXXX preferred shares of the capital stock of DC transferred. ... As a consideration for the purchase for cancellation of the common shares and redemption of the preferred shares of its capital stock held by TC, DC will issue the Promissory Note #2 as payment in full for such purchase for cancellation and redemption. 15. ...