Search - consideration

Results 7851 - 7860 of 8030 for consideration
Technical Interpretation - External

14 March 2002 External T.I. 2001-0089595 - Interation of 250(5) & 128.1(4)(b)(iv)

In order to entitle the successor corporation to the deduction it was imperative that the acquisition of the property of the predecessor by the successor be (a) in exchange for shares of the capital stock of the successor (section 83A(8a)(c) of the former Act) or (b) subsequent to the purchase of shares of the predecessor by the successor in consideration of shares of the successor, as a result of the distribution of such property to the successor upon the winding-up of the predecessor (section 83A(8a)(d) of the former Act). ...
Ruling

2002 Ruling 2002-0152593 - INCORPORATING A MEDICAL PARTNERSHIP

Immediately before this wind up, the Partnership shall have no assets other than the property received from MedCo as consideration for the sale of the Assets referred to in Paragraph 11. ...
Ruling

2002 Ruling 2002-0159043 - INNOVATIVE INSTRUMENT

The surrender of Trust Securities by a holder thereof to the Trust for Preferred Shares XXXXXXXXXX W upon exercise of the Holder Exchange Right as described above in paragraph 14 will be effected by the Trust: (a) converting $XXXXXXXXXX principal amount of the XXXXXXXXXX Note held by it into XXXXXXXXXX Preferred Shares XXXXXXXXXX W in accordance with the terms thereof as set out below, for each Trust Security so surrendered, and (b) redeeming each Trust Security so surrendered in consideration of the transfer to the holder thereof by the Trust of XXXXXXXXXX Preferred Shares XXXXXXXXXX W. 16. ...
Ruling

2003 Ruling 2002-0177363 - Loss Utilization in a Related Group

None of the issued shares referred to herein (including the shares to be issued as described in the Proposed Transactions) are or will be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 21. ...
Ruling

2002 Ruling 2002-016729A - Exploration/Sink Shaft-CEE

X Co. acquired the Property from Y Co. in XXXXXXXXXX for consideration comprised of $XXXXXXXXXX. ...
Ruling

2003 Ruling 2002-0177993 - Safe Income Extraction

However, Canco will not be indemnified against commercial risks and will be subject to market considerations subsequent to its acquisition of the shares of the Newcos and the proposed resale of the Pubco shares. 21. ...
Ruling

2017 Ruling 2015-0605161R3 - Fonds commun de placement (FCP) - Luxembourg

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Sub-Custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...
Technical Interpretation - External

7 March 2000 External T.I. 2000-0002845 - INDIAN TAXATION - DIAND

For purposes of the Guidelines, one must take into consideration the location where the duties of employment are performed, when less than 90% of the duties of employment are performed on a reserve the exemption in Guideline 1 can be prorated. ...
Technical Interpretation - Internal

13 April 2000 Internal T.I. 1999-0011917 - CEE; Resource Allowance; Recovery Expense

Accordingly, although the analysis in Mobil should be given serious consideration in interpreting the word "production", it is critical to note that the wording in section 1204 of the Regulations is quite different than the words in the Excise Tax Act that were the subject of interpretation Mobil. ...
Ruling

2000 Ruling 2000-0018113 - Partial butterfly

In consideration for the transfers described in paragraph 14 above, HoldcoK, HoldcoL and HoldcoM will each issue that number of preferred shares of its capital stock to Amalco having an aggregate fair market value and redemption amount equal to the aggregate fair market value of the property acquired by HoldcoK, HoldcoL and HoldcoM, respectively. 16. ...

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