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Results 721 - 730 of 8030 for consideration
Ruling

1998 Ruling 9825983 - SUPP. TO 3-971606

Newco 3 will subscribe for a nominal number of common shares of each of Newco3Sub1, Newco3Sub2 and Newco3Sub3 for nominal consideration. ... C will subscribe for one common share in the capital of Newco 1, Newco 2 and Newco 4, as the case may be, for nominal consideration. ... Newco 1 will subscribe for a nominal number of common shares of each of Sub-Newco1A and Sub-Newco1B for nominal consideration. ...
Ruling

2012 Ruling 2011-0421261R3 - Partnership Allocation

The Class B Common Shares of BCo were issued for cash consideration to ACo (or a predecessor company) and the Vendors in XXXXXXXXXX, and are currently owned as follows: Shareholder Consideration in XXXXXXXXXX $ Number of Class B Common Shares Issued ACo XXXXXXXXXX XXXXXXXXXX Vendors XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX XXXXXXXXXX 12. ... ACo has subscribed for and GP Co has issued XXXXXXXXXX common shares of GP Co to ACo for an aggregate consideration of $XXXXXXXXXX. ... BCo will receive additional Class A Units of New LP as consideration for the transfer of assets by BCo to New LP, as described in paragraph 21 below, and (b) ACo, which intends to subscribe for Class B Units of New LP for cash consideration from time to time as funds are required by New LP. ...
Ruling

30 November 1996 Ruling 9719643 - INTEREST DEDUCTIBILITY - PUC REDUCTION

The XXXXXXXXXX Note has a principal amount equal to the agreed amount for the purposes of the subsection 85(1) election. 29.The XXXXXXXXXX common shares issued as the balance of the consideration for the XXXXXXXXXX shares had a fair market value equal to the fair market value of the XXXXXXXXXX shares less the principal amount of the XXXXXXXXXX Loan. ... Consideration for the shares of XXXXXXXXXX shares consisted of (i) an interest bearing note payable to XXXXXXXXXX ("XXXXXXXXXX Note 2") and (iii) common shares of XXXXXXXXXX. 42.With respect to the transfer of the XXXXXXXXXX shares, XXXXXXXXXX will file a joint election under subsection 85(1) within the time referred to in subsection 85(6). ... Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...
Technical Interpretation - External

2 April 2001 External T.I. 2001-0068935 - SURROGOCY ARRANGEMENTS

Reasons: The payments are in consideration for services rendered according to our understanding of the contractual relationship between the "Intended Parents" (the payors) and the "Gestational Carrier" (the beneficiary). ... In the case submitted, however, the payments cannot be said to be gifts, that is, voluntary transfers of real or personal property without consideration, since they are required under the surrogacy contract. ... Moreover, the payments are not "without consideration" as the Intended Parents do receive valuable services in exchange, without which no payments would be made. ...
Technical Interpretation - Internal

25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE

A company can issue its own shares as "consideration for the acquisition of property", as Lord Greene M.R. said. ... When the directors of a CBCA corporation determine the consideration for the issue of the shares as consideration for property, it is no different from directors of a corporation deciding to issue a certain number of par value shares as consideration for property. ... Rather than consideration being referable to the product of the par value of the share times the number of shares issued, the consideration is referable to the stated capital of the shares being issued as determined by the directors. ...
Ruling

2008 Ruling 2007-0240271R3 - Purchase and bump

Parent transferred cash to Acquisico 2 in consideration for common shares. d. ... Parent transferred cash to Acquisico 1 in consideration for common shares. e. ... On the Effective Date, Acquisico 2: a. made a loan to Sub 1 in consideration of which Sub 1 issued Note 4; and b. made a loan to GP 1 in consideration of which GP 1 issued Note 5. 27. ...
Ruling

2014 Ruling 2013-0498951R3 - Split-up Butterfly

Each of the XXXXXXXXXX Voting preferred shares and XXXXXXXXXX Non-voting Preferred shares issued by TC1 to Brother will be issued as consideration for a proportionate portion of each of the First common shares and the XXXXXXXXXX of a Class A share of DC transferred to TC1. ... Sister will transfer all of her shares of DC, being XXXXXXXXXX Second Common shares and XXXXXXXXXX of a Class A Special share, to TC2 and, as sole consideration therefor, TC2 will issue XXXXXXXXXX Common shares of TC2 to Sister. ... The Trust will subscribe for XXXXXXXXXX Non-Voting Common shares of TC1 for cash consideration of $XXXXXXXXXX. ...
Ruling

2015 Ruling 2014-0559181R3 - Internal Reorganization

In consideration, Cco will issue Cco Common Shares having a FMV equal to the Class A Common Shares of the capital stock of Bco so transferred. ... In consideration, Dco will issue Dco Common Shares having a FMV equal to the Class A Common Shares of the capital stock of Bco so transferred. ... In consideration, Eco will issue Eco Common Shares having a FMV equal to the Class A Common Shares of Bco so transferred. ...
Ruling

2096 Ruling 9600293 - FULL GROSS-BASIS BUTTERFLY, PERMITTED REDEMPTION, LOSSES

The authorized share capital of XXXXXXXXXX will include voting preferred shares, redeemable and retractable for an amount equal to the fair market value of the consideration for which these shares are issued. XXXXXXXXXX will subscribe for XXXXXXXXXX common shares of XXXXXXXXXX for an aggregate consideration of $XXXXXXXXXX will subscribe for XXXXXXXXXX common shares of XXXXXXXXXX for an aggregate consideration of $XXXXXXXXXX The class XXXXXXXXXX special shares of Amalco issued to Holdings as described in paragraph 9 above will be redeemed for their redemption amount of $XXXXXXXXXX per share. ... Following the completion of the transfer of the properties as described in paragraph 16 above, Sub A and Sub B will redeem the preferred shares issued to Amalco as consideration for the transfer of assets. ...
Ruling

2002 Ruling 2002-0136163 - 1103(2d) Election on 1102(14) Property

OT gave Pubco a $XXXXXXXXXX demand note (the "OT Note") as consideration. 21. ... Opco will receive share consideration in respect of each eligible property transferred to Sub1. 29. ... The agreed amount in respect of each eligible property will not be less than the non-share consideration received by Opco as consideration for that property. ...

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