Search - consideration

As consideration for the transfer, Holdco A will receive non-voting, non-participating, fixed-value preferred shares of Realco. ... As consideration for the share redemptions, Realco will issue a demand promissory note to Opco. 6. ... As consideration for the share redemptions, Opco will issue a demand promissory note to Realco. 7. ...

In your particular situation, the quit claim signed by the farmer in consequence of the "Consideration Agreement", facilitated the agreement and not any foreclosure action. ... The nature of the transaction was one where property was transferred to the bank for consideration. ... -Our statement was made in conjunction with a statement we made that "if the guarantee has been given for adequate consideration, it will generally be considered to have been given for the purpose of gaining or producing income. ...

The Agreement provides, among other things, for: (i) the sale of the Software and certain other business assets of Company B to Newco for cash; (ii) the sale of certain business assets, other than the Software and the assets described in (i), of Company B to Newco for consideration consisting of shares of Newco; and (iii) the sale of certain business assets of Company A to Newco for consideration consisting of shares of Newco. ... Company A will sell substantially all of its business assets to Newco for consideration consisting of Class A Preference shares. Company B will sell its remaining business assets to Newco for consideration consisting of Class A Preference shares. 13. ...

He received no consideration for making the guarantee. 2. XXXXXXXXXX. 3. ... If the guarantee has been given for adequate consideration, it will generally be considered to have been given for the purpose of gaining or producing income. ... The Department's position regarding guarantees or loan for inadequate consideration has been challenged successfully in such cases as Business Art Inc. v. ...

Would our views change if instead of a non-interest bearing loan services were provided for less than fair market value consideration. ... Whether our views would change if Canco provided services to LLC1 for no consideration rather than issuing a non-interest bearing loan. ... It would seem reasonable to be of the view that services provided to LLC1 for no consideration would result in an increase in fair market value of the shares of LLC1. ...

(footnote 1) Qualifying revenue means the inflow of cash, receivables, or other consideration arising in the course of the ordinary activities of the eligible entity in Canada in a particular period. ... Not typical of the normal activities or risks inherent in the normal operations of the entity o Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c. Primarily out of the control of owners or management o Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

Consideration for the transfer consisted of shares of Corporation Z, (equal to 66 2/3% of the value of the shares of Corporation X transferred to Corporation Z), and assumption by Corporation Z of debt owing by Mr. ... Further, since all or substantially all of the consideration received by Mr. ... A from Corporation Z in respect of the shares of Corporation X was not shares of Corporation Z (because 33 1/3% of the consideration consisted of assumption of debt owing by Mr. ...

On incorporation, NewCo A will subscribe for at least one SubCo A Common Share for nominal consideration. Similarly, NewCo B will subscribe for at least one SubCo B Common Share for nominal consideration and NewCo C will subscribe for at least one SubCo B Common Share for nominal consideration. ... As consideration therefor, each of SubCo A, SubCo B and SubCo C, as the case may be, will issue to DC in consideration therefor a non-interest-bearing demand promissory note having a principal amount and fair market value equal to the aggregate redemption amounts of such SubCo's shares so redeemed. ...

Each of PARENT and OPCO contributed $XXXXXXXXXX to LP as consideration for one unit each in LP. 19. ... PARENT will transfer its operations situated in XXXXXXXXXX to GP2 in consideration for the issuance by GP2 of partnership units. ... PARENT will subscribe for XXXXXXXXXX preferred shares in the capital of Holdco in consideration for the payment of $XXXXXXXXXX. ...

Is the payment made as consideration for a rate deduction deductible? ... Although the tax treatment of a payment "..as consideration for a reduction in the rate of interest payable by a taxpayer on the debt obligation" is provided for under paragraph 18(9.1)(c) and subparagraph 18(9.1)(f)(i) of the Act, which applies " in the case of a reduction described in paragraph (c)... ... When subsection 18(9.2) applies to the exclusion of subsection 18(9.1) of the Act, the payment made as consideration for a reduction in the rate of interest payable on the debt obligation is deemed to be a prepayment of interest payable in a future year, and the result is a lower deduction in earlier years, increasing over time based on what would have been the remaining term of the debt obligation. ...