Search - consideration

NR Target owns high value, low PUC shares of a Canadian operating corporation (CanOpco). 3) NR Target then sells the shares of CanOpco to CanAc in consideration for a Note Receivable in an amount equal to the fair market value of the shares of CanOpco. ...

However, it is not uncommon for a shareholder to request an S Corporation Agreement and, while the request is under consideration, to file a Canadian tax return on the expectation that an S Corporation Agreement will be provided. ...

In the Duha Printers decision of the Supreme Court of Canada, which dealt with whether there had been an acquisition of control of a corporation, that Court held that in determining whether a majority shareholder enjoys effective control over the affairs of a corporation, consideration must be given to the corporation's governing statute, its share register, its constating documents or any USA. ...

. / When an emphyteusis is made for consideration, the amount provided, whether payable by lump sum or by installments, is regarded as the proceeds of disposition of a right of emphyteusis or part or all of the property subject to the emphyteusis. ...

Subsection 214(7) and its Interaction with the Definition of "Participating Debt Interest" The more difficult issue is whether the deemed payment of interest under subsection 214(7) of the ITA would constitute participating debt interest because of the application of the deeming rule in subsection 214(7) in the context of a particular transaction involving standard convertible debentures, and taking into consideration the terms and conditions of a particular standard convertible debenture (including anti-dilution provisions). ...

If Canco seconds employees to a foreign affiliate of Canco in consideration for a fee equal to its cost (i.e. the employees' remuneration) plus a 25% mark-up, will the service business income of the foreign affiliate be recharacterized as FAPI pursuant to subparagraph 95(2)(b)(ii) of the Act as a result of the services provided by the seconded employees from Canco? ...

., by way of a submitted Topic Selection Form) receive priority consideration for updates? ...

Generally, a plan will be considered a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement. ...

The IRS is continuing to assess the scope and impact of the Court's decision while consideration is given to options for appeal. ...

The XXXXXXXXXX (hereinafter "NPO") sold its assets to XXXXXXXXXX for a consideration of $XXXXXXXXXX. ...