Search - consideration

During 1997, XXXXXXXXXX Class XXXXXXXXXX non-voting shares were issued under the stock option plan for total cash consideration of $XXXXXXXXXX. ... As sole consideration for such transfer, Newco will issue, to Opco, Newco special shares having an aggregate stated capital not exceeding the agreed amount for the XXXXXXXXXX shares and an aggregate redemption amount and FMV equal to the FMV of the XXXXXXXXXX shares. ... Newco will redeem from Opco all of its Newco special shares for an amount equal to the aggregate of the Newco Redemption Amount (as defined in Paragraph 12(a)) of all the Newco special shares (hereinafter referred to as the "Newco Redemption Amounts") so redeemed and will issue to Opco in consideration therefor a demand promissory note (hereinafter referred to as the "Newco Redemption Note") with a principal amount and FMV equal to the aggregate of the foregoing Newco Redemption Amounts. ...

For greater certainty, for the purposes of each election described above, the agreed amount will not exceed the amount of any non-share consideration paid by such Newco in respect of the particular transferred property. ... The terms of the Class Y Preferred Shares to be issued by each of Newco A, Newco B, Newco C, Newco D and Newco E, as the case may be, issued as consideration for its pro-rata share of Holdings' Assets, as described in Paragraph 17, will provide that such shares will: (a) be non-voting; (b) be redeemable and retractable at an amount equal to the aggregate fair market value of the pro-rata share of Holdings' Assets transferred to the particular Newco less the amount of any liabilities assumed by the particular Newco on such transfer, together with all accrued and unpaid dividends and subject to a purchase price adjustment as described below (the "Class Y Redemption Amount"); (c) have an aggregate stated capital equal to the aggregate of the elected amounts (where an election was made under subsection 85(1)) or the transfer price (where no election was made under subsection 85(1)) in respect of such transferred Assets received by such Newco, as described in Paragraph 17 above, less the amount of any non-share consideration paid by such Newco for its portion of the Assets transferred by Holdings; (d) entitle a holder to non-cumulative dividends at a rate reasonably determined to be a market dividend rate at the time the shares are issued; and (e) subject to the rights of any shares ranking in priority to or on parity with the Class Y Preferred Shares, entitle a holder to the Class Y Redemption Amount on the wind-up, liquidation or dissolution of the Newco in priority to any return to the holders of the common shares. ... Subject to the application of subsection 69(11), the provisions of subsection 85(1) will apply to: (i) each transfer of Class A Shares and Special Shares of Holdings owned by Parent to each Newco as described in Paragraphs 13; (ii) each transfer of Common Shares of Holdings owned by Sibling1, Sibling2, Sibling3 and Estate, as the case may be, to such Newco as described in Paragraph 15; and (iii) each transfer of eligible property owned by Holdings to each Newco as described in Paragraph 17 such that the agreed amount in respect of each transfer described above will be deemed to be the transferor's proceeds of disposition of the particular property and the transferee's cost thereof, and, after deducting the amount of any non-share consideration received by the transferor, the transferor's cost of the shares received as consideration for such disposition. ...

As consideration for providing or arranging for the provision of production services, the Production Co. will receive a production services fee from Studio. ... As consideration therefor, the Producer will receive a fee from Studio equal to the aggregate of: (a) XXXXXXXXXX; and (b) XXXXXXXXXX. 11. ... As consideration therefor, the Production Services Partnership will pay the XXXXXXXXXX Fee to Production Co. 13. ...

As consideration for the transfer, Mr. A will receive Class A common shares in the capital of TC1 with an aggregate FMV equal to the aggregate FMV, at the time of the transfer, of the DC shares transferred to TC1. ... As consideration for the transfer, Mr. B will receive Class A common shares in the capital of TC2 with an aggregate FMV equal to the aggregate FMV, at the time of the transfer, of the DC shares transferred to TC2. ... As consideration therefor: (a) TC1 will issue a promissory note which will have a principal amount and FMV equal to the aggregate FMV and the redemption amount of the TC1 Preferred Shares (“Promissory Note #1”); and (b) TC2 will issue a promissory note which will have a principal amount and FMV equal to the aggregate FMV and the redemption amount of the TC2 Preferred Shares (“Promissory Note #2”). ...

In these circumstances, the parties may negotiate a purchase price adjustment that reflects the funded status of the plan to take into consideration the overall financial effect of transferring the pension obligations. ... Because the parties to the ATA in this case chose to assign sponsor responsibilities to the Purchaser, there was no requirement under the PBA that consideration be paid for the Surplus Amount by the Purchaser to the Seller. ... This is relevant because the deductibility of the Surplus Amount depends in part on whether it represents consideration paid for this equitable interest for purposes of the exclusion in paragraph (f) of the ECE definition. ...

This would include the consideration of a “normal redetermination period.” ... This would include the consideration of a “normal redetermination period”. ... That being said, if such a taxpayer’s request is due to a taxpayer’s desire to amend or revoke an election under section 125.7, consideration must be given to subsection 125.7(10). ...

Neuman’s wife subscribed for class “F” shares of the corporation in exchange for a consideration of $99. ... In consideration, it would receive shares of Opco Z of the same type and having the same value. ... Department of Finance reply The same considerations were raised in question 41. ...

No other consideration was given by Trust 2 to such unitholders for their units of Trust 2. ... (collectively the "Shares") were sold by Trust 1 to Z Co. for consideration consisting solely of XXXXXXXXXX common shares of Z Co. ... The amount so agreed upon in respect of a particular asset will not be less than the fair market value, at the time of the sale, of the consideration (other than Preferred Shares) received by the New Trust therefore. ...

In addition, each GC 5Co class H preferred share is non-voting, non-participating, and redeemable and retractable at an amount equal to the FMV of the consideration received for the issuance of the share. ... In addition, each GC 12Co fifth preferred share is non-voting, non-participating, and redeemable and retractable at an amount equal to the FMV of the consideration received for the issuance of the share. ... For the purposes of the BCA, the addition to the stated capital account of the TC Preferred Shares issued by each such TC to DC as consideration for the Distribution Property transferred by DC to each such TC, will be an amount of one dollar. 53. ...

The sole consideration issued by Spinco for each DC Butterfly Share will be one Spinco Common Share. ... As sole consideration for such transfer, DC will issue a promissory note (the "Sale Note") to Subco 1 having a principal amount and FMV equal to the aggregate FMV of the Subco 1 Retained Business so transferred to DC at that time. 32. ... As sole consideration for the Transferred Assets, Spinco will issue Spinco Redemption Shares to DC, having an aggregate FMV equal to the aggregate FMV of the Transferred Assets. ...