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Results 5151 - 5160 of 8027 for consideration
Ruling

2004 Ruling 2003-0046771R3 - split-up butterfly

As consideration for the transfer, Old DC issued XXXXXXXXXX of its common shares ("Old DC Common Shares") to the Partnership. ... As sole consideration for such transfer, TC will issue XXXXXXXXXX TC Class B Common Shares to B2 having an aggregate FMV equal to the aggregate FMV at that time of the XXXXXXXXXX DC Class B Common Shares that B2 so transferred to TC. ... Immediately following the transfer of property as described in paragraph 12, TC will redeem from DC all of its Class D Shares and will issue to DC in consideration therefor, a demand non-interest bearing promissory note having a principal amount and FMV equal to the aggregate redemption amount and FMV of its Class D Shares (the "TC Redemption Note") so redeemed. ...
Ruling

2004 Ruling 2004-0070491R3 - Loss Consolidation

On or prior to XXXXXXXXXX, Newco Two will purchase for cancellation the one issued and outstanding common share of Newco Two held by LOSSCO for cash consideration equal to the fair market value thereof. ... BCO will transfer all of the shares of XCO that it owns to Newco Two for consideration consisting of Newco Two Preferred Shares with a redemption amount equal to the fair market value of the transferred XCO shares. ... Newco Two will transfer all of the XCO shares that it acquired from BCO in paragraph 17 above to Subco for consideration consisting of one common share of Subco. ...
Ruling

2004 Ruling 2004-0074311R3 - Income Trust

In these circumstances, the Fund will exercise its right to require the Trust to redeem Series 1 Trust Notes of the Trust in consideration for the issuance to the Fund of Series 2 Trust Notes having an aggregate principal amount equal to the amount of the in specie redemption. ... The Trust will contribute a portion of the proceeds received from the Fund to LP1 in consideration for units of LP1. ... The Trust will use the remaining proceeds received from the Fund (net of costs and expenses incurred by the Trust) to purchase from NewHoldco: (i) all of the issued and outstanding shares of Newco1 (in consideration for cash), and (ii) all of the units of LP1 held by NewHoldco (in consideration for cash, Class A Fund Units and Class B Fund Units). 41. ...
Ruling

2000 Ruling 2000-0014603 - Internal Reorganization

DC2 will subscribe for one YCO Class B Share for nominal consideration. 11. ... DC1 will transfer the XCO Designated Preferred Shares to YCO in consideration for the issuance by YCO to DC1 of YCO Preferred Shares with an aggregate redemption amount and fair market value equal to the aggregate redemption amount and fair market value of the XCO Designated Preferred Shares. ... XCO will transfer the Designated Assets to YCO in consideration for (a) the issuance by YCO to XCO of YCO Special Shares, (b) the payment of the Daylight Loan Proceeds to XCO and (c) the assumption of the XCO Designated Current Debt. ...
Ruling

2000 Ruling 2000-0008363 - Mutual Fund Large Investor Incentive

In consideration for its management activities relating to each of the Trusts, the Manager earns a fee (a "Management Fee"). ... A unitholder will not be entitled to receive any consideration upon the conversion of Class A units to Class B units other than Class B units. 20. ... A unitholder will not be entitled to receive any consideration upon the conversion of Class B units to Class A units other than Class A units. ...
Ruling

2000 Ruling 2000-0035503 - Reorganization, 55(3)(b)

As consideration for the transfer, Holdings will issue to each transferor a number of its Common Shares having a FMV equal to that of the Aco shares so received. ... As consideration for the transfer, Holdings will assume certain liabilities of Aco and issue a number of Holdings Redeemable Shares to Aco. ... As consideration, Aco will issue a demand promissory note having a face amount and principal amount equal to the aggregate purchase price of the shares so purchased (the "Aco Note"). ...
Ruling

1999 Ruling 9914063 - BUTTERFLY REORGANIZATION

The amount to be specified in respect of each Preferred Share, at the time of its issuance by a resolution to be made by the Board of Directors, will be expressed as a dollar amount, will not be determined by a formula and will be equal to the FMV of the property received as consideration for such share. ... No non-share consideration shall be paid. 42. Shareholder 1 and Transferee will jointly elect under subsection 85(1), in prescribed form and within the time limits prescribed by subsection 85(6), in respect of the Common Shares so transferred. ... Distributor will pay the purchase or redemption price for such shares by issuing to Transferee a non-interest bearing demand promissory note having a principal amount and FMV equal to the FMV of the Common and Preferred Shares so purchased or redeemed for consideration ("Distributor Note"). ...
Ruling

2020 Ruling 2019-0817051R3 - Reorganization

At XXXXXXXXXX, Foreign Parent directly acquired all of the issued and outstanding shares of Parent Amalco pursuant to the Arrangement by issuing consideration having a FMV of approximately $XXXXXXXXXX to the shareholders and option holders of Parent Amalco. ... XXXXXXXXXX of such amount was loaned to Parent Amalco, which loan is evidenced by the Canco 10 Note, and the remainder of such amount was transferred in consideration of the transfer by Parent Amalco of $XXXXXXXXXX from its Canadian dollar treasury account to Canco 10’s Canadian dollar operating account, such being the Canadian dollar equivalent of the balance on the date of transfer. 52. ... Parent Amalco directed Corporation Amalco to retain the amount owed to it pursuant to such redemption in repayment of $XXXXXXXXXX of the amount owing under the Excess Cash Note. 60.2 On XXXXXXXXXX, Partnership sold Project 1 and all of the shares of Canco 12 in consideration for cash of $XXXXXXXXXX, subject to certain post-closing adjustments. 60.3 On XXXXXXXXXX, Partnership loaned the proceeds received in Paragraph 60.2 to Corporation Amalco pursuant to a non-interest bearing note due XXXXXXXXXX. 60.4 On XXXXXXXXXX, Corporation Amalco redeemed XXXXXXXXXX Class A Preferred Shares held by Parent Amalco in consideration for $XXXXXXXXXX, and used the amount it was loaned in Paragraph 60.3 to satisfy such redemption proceeds. ...
Ruling

2022 Ruling 2020-0873371R3 - Multi-wing split-up net asset butterfly

As the final step in the Prior Reorganization, General Partner sold its DC Common Shares to Holdco 6 in consideration for a non-interest-bearing promissory note; vii. ... The amount to be specified will be expressed as a dollar amount (and not determined by a formula), will not exceed the FMV of the consideration for which each TC2 Butterfly Share is issued and will not be subject to change thereafter. ... For the purposes of subsection 191(4), the DC Butterfly Shares, TC1 Butterfly Shares and TC2 Butterfly Shares will not be issued for consideration that includes a taxable preferred share. 75. ...
Ruling

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly

On XXXXXXXXXX, Canco sold a group of XXXXXXXXXX Canadian corporations (the "XXXXXXXXXX Sale") to an unrelated purchaser for consideration of US$XXXXXXXXXXXXXXXXXXXX, comprised of $XXXXXXXXXX in cash paid by the purchaser on closing and the issuance of XXXXXXXXXX Note 1 and XXXXXXXXXX Note 2. ... As consideration for such property, TCo issued TCo Preferred Shares to DC having an aggregate FMV equal to: (a) the aggregate FMV of the Newco Common Shares so transferred to TCo at that time, and (b) the Additional Cash Transfer that DC is legally obligated to transfer to TCo as described in Paragraph 58.1. ... The amount added to the Capital Account of TCo in respect of the issuance of the TCo Preferred Shares was an amount equal to the aggregate FMV at that time of the total consideration paid to TCo for the issuance of the TCo Preferred Shares. ...

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