Search - consideration
Results 41 - 50 of 8030 for consideration
Ruling
2021 Ruling 2021-0911211R3 - Foreign Takeover
Payment of Merger Consideration and Financing of the Acquisition 23. The former holders of Target shares received the Merger Consideration as soon as practicable after the Closing Date. As required by the Merger Agreement, prior to the First Effective Time, XXXXXXXXXX, on behalf of Merger Sub1, caused to be deposited, XXXXXXXXXX, in trust for the benefit of holders of Target shares, the Merger Consideration, XXXXXXXXXX sufficient to pay the aggregate Cash Consideration and evidence of XXXXXXXXXX Common Shares in book-entry form representing the number of XXXXXXXXXX Common Shares sufficient to deliver the aggregate Share Consideration. 24. ... Upon the issuance of the XXXXXXXXXX Common Shares as the aggregate Share Consideration as described in Paragraph 33.ii, XXXXXXXXXX, added to the stated capital account maintained for such common shares an amount equal to the aggregate FMV of the Share Consideration. ...
Technical Interpretation - Internal
1 September 2015 Internal T.I. 2015-0605491I7 - In-kind transfer of property from an RRSP to an IPP
Other Considerations The advantage rules do not appear to have any application to the specific type of transfer that you raise in your letter (i.e. a transfer of property from an RRSP to an IPP in accordance with paragraph 146(16)(a)), but could conceivably apply in other situations where individuals effect transactions between their RRSP and an IPP. ...
Technical Interpretation - Internal
13 September 2001 Internal T.I. 2001-0083067 - HEALTH AND WELFARE TRUSTS
Other Considerations A) The determination of whether a benefit is received by an employee-shareholder in his/her capacity as an employee or as a shareholder involves a finding of fact. ...
Technical Interpretation - Internal
24 January 2001 Internal T.I. 2000-0059517 - DISPOSITION OF PARTNERSHIP AT DEATH
Canadian Resource Property Considerations First of all, it has been the long-standing view of the Department/Agency that an interest in a partnership, the underlying property of which is a Canadian resource property (as defined in subsection 66(15) of the Act), is not a Canadian resource property itself (1). ...
Technical Interpretation - External
28 April 1995 External T.I. 9501085 - TRANSFER OF RRSP FUNDS TO CHARITY ISSUED ANNUITY
Other Considerations: In addition to the rules respecting qualified investments for RRSP's, certain registration requirements will affect the manner in which the annuity purchase is handled. ...
Technical Interpretation - External
25 November 2005 External T.I. 2005-0122351E5 - Service Connection and CRCE
Other Considerations It should be noted that a proposed amendment to Class 17 of Schedule II to the Regulations, which was announced on March 16, 2001, provides that electrical generating equipment (subject to certain exceptions that are not relevant to your situation) acquired after February 27, 2000 will be included in that class by virtue of proposed paragraph (a.1) thereof. ...
Technical Interpretation - Internal
3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef
In determining the value of benefit, one may take its cost into consideration. ... Considération des dépenses de la société pour déterminer la valeur d'un avantage imposable Évaluation de l'avantage imposable en fonction des frais de fonctionnement et de la DPA 68. ... Les considérations du juge nous amènent à conclure qu'une méthode d'évaluation de la valeur d'un avantage fondée sur les frais de fonctionnement et la DPA peut être adéquate dans certaines circonstances pourvu qu'elle se rapproche de la JVM. ...
Technical Interpretation - External
17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project
General Tax Considerations Relating to Different Aspects of the Project 1. ...
Ruling
2009 Ruling 2008-0275881R3 - Butterfly reorganization
On XXXXXXXXXX, A subscribed for XXXXXXXXXX Class A voting preferred shares in PC1 for a $XXXXXXXXXX cash consideration. ... The consideration issued by each Holding Company 82. The consideration to be received by DC on the Distribution to each Holding Company will be a combination of assumed liabilities and XXXXXXXXXX Class A preferred shares. 83. ... The Corporate Group was primarily restructured prior to A's death for estate planning considerations. 101. ...
Ruling
2010 Ruling 2008-0279961R3 - Butterfly reorganization
A will transfer the XXXXXXXXXX Class A PS, XXXXXXXXXX Class C PS and XXXXXXXXXX Class E PS it held in DC to Aco in consideration for the Aco Debt 1, which has a Principal Amount equal to the aggregate FMV (and PUC) of the Class A PS, Class C PS and Class E PS in DC transferred to ACo. 21. ... B will transfer the XXXXXXXXXX Class A PS, XXXXXXXXXX Class C PS and XXXXXXXXXX Class E PS it held in DC to Bco in consideration for the Bco Debt 1, which has a Principal Amount equal to the aggregate FMV of the Class A PS, Class C PS and Class E PS in DC transferred to ACo. 25. ... BCo will redeem the XXXXXXXXXX Class C Special Shares of its capital stock owned by DC for an amount equal to their Issue Price, and will issue to DC the BCo Note as a consideration for the redemption of the XXXXXXXXXX Class C Special Shares so issued by ACo and BCo. 39. ...