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Results 731 - 740 of 8030 for consideration
Ruling
1998 Ruling 9733833 - 55(3)(A) RULING
The shares of E Co. were sold to an unrelated third party for fair market value cash consideration. ... As consideration for the transfer of property described herein, Newco will pay cash to Subco2. 10. ... As consideration for the transfer of the property as described herein, the Trust will pay cash to Subco3. ...
Ruling
2011 Ruling 2009-0335251R3 - Subsection 87(11) and paragraphs 88(1)(c) and (d)
On XXXXXXXXXX, XXXXXXXXXX [UKCo4] subscribed for additional shares of XXXXXXXXXX [UKCo3] for cash consideration of US$XXXXXXXXXX. 16. ... On XXXXXXXXXX, XXXXXXXXXX [USCo3] subscribed for XXXXXXXXXX common shares in XXXXXXXXXX [USCo6] for cash consideration of US$XXXXXXXXXX. ... At points between these two amounts, a pro-rata portion of the remaining unpaid contingent consideration is payable. ...
Ruling
2006 Ruling 2006-0209121R3 - Internal Reorganization - 55(3)(a)
The Redemption Amount of a Non-Voting Preference Share will be equal to the aggregate fair market value of the property received by the company in return for the issuance of such shares less any non-share consideration paid by the company for such property on their issuance, divided by the number of shares so issued. ... XXXXXXXXXX) of her Class D Shares of Investco to each of the Holdcos and as consideration therefor, each Holdco will issue an equal number of its Class D Preferred Shares to Parent having an aggregate FMV equal to the aggregate FMV of the Class D Shares of Investco transferred to that Holdco by Parent; (c) one-fifth of her remaining Class E Shares of Investco to each of the Holdcos and as consideration therefor, each Holdco will issue an equal number of its Class E Preferred Shares to Parent having an aggregate FMV equal to the aggregate FMV of the Class E Shares of Investco transferred to that Holdco by Parent. ... On a contemporaneous basis with the share transfers described in Paragraphs 17 and 18: (a) Trust1 will transfer its XXXXXXXXXX Common Shares of Investco to Holdco1 and as consideration therefor, Holdco1 will issue XXXXXXXXXX of its common shares to Trust1 having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX Common Shares of Investco transferred to Holdco1 by Trust1; (b) Trust2 will transfer its XXXXXXXXXX Common Shares of Investco to Holdco2 and as consideration therefor, Holdco2 will issue XXXXXXXXXX of its common shares to Trust2 having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX Common Shares of Investco transferred to Holdco2 by Trust 2; (c) Trust3 will transfer its XXXXXXXXXX Common Shares of Investco to Holdco3 and as consideration therefor, Holdco3 will issue XXXXXXXXXX of its common shares to Trust3 having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX Common Shares of Investco transferred to Holdco3 by Trust 3; (d) Trust4 will transfer its XXXXXXXXXX Common Shares of Investco to Holdco4 and as consideration therefor, Holdco4 will issue XXXXXXXXXX of its common shares to Trust4 having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX Common Shares of Investco transferred to Holdco4 by Trust 4; and (e) Trust5 will transfer its XXXXXXXXXX Common Shares of Investco to Holdco5 and as consideration therefor, Holdco5 will issue XXXXXXXXXX of its common shares to Trust5 having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX Common Shares of Investco transferred to Holdco5 by Trust 5. ...
Ruling
2005 Ruling 2005-0149021R3 - XXXXXXXXXX - Internal Reorganization
Sibling A Holdco will issue: XXXXXXXXXX Class B Shares to Parent as consideration for the XXXXXXXXXX Investco Class B Shares transferred to Sibling A Holdco by Parent; and XXXXXXXXXX Class D Shares as consideration for the XXXXXXXXXX Investco Class D Shares transferred to Sibling A Holdco by Parent. ... Sibling B Holdco will issue: XXXXXXXXXX Class B Shares to Parent as consideration for the XXXXXXXXXX Investco Class B Shares transferred to Sibling B Holdco by Parent; and XXXXXXXXXX Class D Shares as consideration for the XXXXXXXXXX Investco Class D Shares transferred to Sibling B Holdco by Parent. ... As consideration therefor, Sibling C Holdco will issue XXXXXXXXXX of its Common Shares to Sibling C Family Trust. ...
Ruling
2021 Ruling 2020-0843131R3 - XXXXXXXXXX Butterfly
As consideration for the property transferred by DC to TC1, TC2 and TC3, TC1, TC2 and TC3, as the case may be, will: a. assume an amount of DC’s existing liabilities; and b. ... As consideration therefor, DC will issue to TC1 the DC Redemption Note 1 equal to the aggregate FMV and/or aggregate redemption amount of the shares so purchased for cancellation or redeemed. ... As consideration therefor, DC will issue to TC2 the DC Redemption Note 2 equal to the aggregate FMV and/or aggregate redemption amount of the shares so purchased for cancellation or redeemed. ...
Ruling
2000 Ruling 2000-0048083 - butterfly reorganization
The aggregate FMV of the consideration will equal the FMV of the XXXXXXXXXX Transferred Assets. 21. ... X may transfer to XXXXXXXXXX/PUBCO for FMV consideration, shares of XXXXXXXXXX or cause to be transferred to XXXXXXXXXX/PUBCO for FMV consideration, assets of XXXXXXXXXX. ... X, as consideration for such transfer, XXXXXXXXXX/PUBCO will issue to XXXXXXXXXX/Mr. ...
Ruling
2001 Ruling 2001-0084793 - Butterfly
A will transfer to Aco his XXXXXXXXXX Cco XXXXXXXXXX Shares in consideration for XXXXXXXXXX Aco XXXXXXXXXX Shares. ... Aco will transfer to Tco all the shares it owns in Cco in consideration for XXXXXXXXXX Tco Common Shares. ... Bco will transfer to Uco all its shares of Cco in consideration for XXXXXXXXXX Uco Common Shares. ...
Ruling
1999 Ruling 9924123 - CORPORATE GROUP LOSS UTILIZATION SCHEME
As consideration, XXXXXXXXXX will surrender its four notes receivable. 33. ... As consideration, XXXXXXXXXX will surrender its four notes receivable. 51. ... As consideration, XXXXXXXXXX will surrender its four notes receivable. 69. ...
Ruling
2002 Ruling 2002-0140733 - XXXXXXXXXX - Sequential Butterfly
(d) XXXXXXXXXX will transfer all of the shares of XXXXXXXXXX to Holdco and as sole consideration therefor, Holdco will issue a number of common shares to XXXXXXXXXX that have a FMV equal to the aggregate FMV of such transferred property. ... The AF Subco Class A Special Shares will be redeemable and retractable for an amount (the "AF Subco Class A Redemption Amount") equal to the FMV of the consideration received by AF Subco upon the issuance of such shares. ... The BF Subco Class A Special Shares will be redeemable and retractable for an amount (the "BF Subco Class A Redemption Amount") equal to the FMV of the consideration received by BF Subco upon the issuance of such shares. ...
Ruling
2005 Ruling 2004-0104851R3 - Single-wing Spilt-up Butterfly
As consideration for the transfer of the DC-Sub-2 Pubco Shares, Subco will issue XXXXXXXXXX common shares. ... DC-Sub-1 and DC-Sub-2 will each only receive cash from the third party as consideration therefor. ... None of the Transferee2-Sub Preferred Shares will be issued for consideration that includes a taxable preferred share. 22. ...