Search - consideration

The initial Foreign Spinco XXXXXXXXXX was issued to Forco 3 for consideration of USD$XXXXXXXXXX. ... On incorporation, Foreign Spinco subscribed for XXXXXXXXXX TC Common Shares for an aggregate consideration of $XXXXXXXXXX. ... On XXXXXXXXXX, DC subscribed for Partnerco Common Shares for an aggregate consideration of $XXXXXXXXXX. 116. ...

The Fund will subscribe for that number of Class A Shares of Newco as is equal to the number of its issued and outstanding Fund Units (other than those held by designated beneficiaries) in consideration for a cash payment of $XXXXXXXXXX per Class A Share (the "Class A Share Subscription Proceeds"). 29. The Fund will subscribe for that number of TRUST Special Units as is equal to the number of its issued and outstanding Fund Units (other than those held by designated beneficiaries) plus $XXXXXXXXXX in consideration for a cash payment of $XXXXXXXXXX per TRUST Special Unit. 30. ... No consideration other than TRUST Special Units will be received by the Fund Unitholders on the redemption of the Class A Shares and no consideration other than TRUST Ordinary Units will be received by TRUST on the redemption of the Class B Shares. 37. ...

None of the Class B Shares of TC will be issued for consideration that includes a taxable preferred share. One common share of TC will be issued to Individual2 for nominal consideration on incorporation. 16. ... As consideration therefor, TC will issue a non-interest bearing demand promissory note to DC (the "TC Note") having a principal amount and FMV equal to the aggregate Redemption Amount and FMV of the Class B Shares so redeemed by TC. ...

As the sole consideration for the transfer, Transferee 1 will issue common shares to Shareholder 1. ... As the sole consideration for the transfer, Transferee 2 will issue common shares to Shareholder 2. ... As the sole consideration for the transfer, Transferee 3 will issue common shares to Shareholder 3. ...

Subsection 247(12) deems a Canadian resident to have paid a deemed dividend where there is an income adjustment under 247(2) resulting from a purchase for consideration that exceeds the amount that would meet the arm’s length principle or from a sale for consideration that is lower than such amount. ... The economic position of the Canadian resident and the non-resident is substantively identical whether the Canadian resident sells for insufficient consideration or buys for excessive consideration. ... Where the non-resident purchases for consideration that is lower than the amount that meets the arm’s length principle, the deemed dividend takes the form of the excess of such amount over the consideration that it paid for the property or in other words, of the excess of the value of the property acquired over the consideration paid for it. ...

The following examples illustrate several situations in which CRA may give favourable consideration. ... CRA will generally give favourable consideration to a request for waiver of the advantage tax in this situation. ... Upon learning of the share redemption later in 2012, the taxpayer takes immediate action and swaps the shares out of the RSRP for fair market value consideration. ...

Therefore, GST/HST is not exigible on the payments in consideration for the right. ... X in consideration for the granting of a right or licence to extract aggregates from his property represent income from property. ... Pursuant to subsection 162(2) of the ETA, the supply of the right is deemed not to be a supply and the consideration paid in respect of that right is deemed not to be consideration for the right. ...

If Opco repurchases 99.99% of the shares of the capital stock of Opco held by Holdco instead of paying a dividend, would paragraph 55(3)(a) apply with respect to the deemed dividend considering that the cash paid to Holdco in consideration of the repurchase is not supported by safe income and considering that the ACB of the shares repurchased is nominal? ... The CRA could find abusive a situation where cash is distributed to Holdco in consideration for the repurchase or redemption of shares of the capital stock of Opco (even if the cash was owned by Opco at the beginning of the series) if the cash does not come from income taxed in Opco. ... Question 2 Selon votre situation hypothétique, l’argent reçu par Gestion en considération de l’achat de gré à gré des actions du capital-actions d’Opco était détenu par Opco au début de la série mais ne provenait pas du revenu imposé dans les mains d’Opco (ne provenait donc pas du revenu protégé d’Opco). ...

The shareholders of XXXXXXXXXX exchanged their shares for a combination of new Class XXXXXXXXXX Shares, Class XXXXXXXXXX Shares, and Class XXXXXXXXXX Shares of XXXXXXXXXX. 11.On XXXXXXXXXX, immediately following the amalgamation and share exchange to form XXXXXXXXXX, a wholly owned subsidiary of Canholdco, XXXXXXXXXX (“Acquisition Co.”) acquired all of the outstanding Class XXXXXXXXXX Shares of XXXXXXXXXX from the public shareholders for cash consideration of $XXXXXXXXXX. 12.Also on XXXXXXXXXX, Acquisition Co. subscribed for XXXXXXXXXX common shares of XXXXXXXXXX for cash consideration of $XXXXXXXXXX. ... The full amount of $XXXXXXXXXX was added to the stated capital account of Canholdco. 14.On XXXXXXXXXX, as a result of the transactions in paragraphs 11 and 13, Acquisition Co. acquired control of XXXXXXXXXX. 15.The total cash consideration of $XXXXXXXXXX paid by Acquisition Co. to acquire control of XXXXXXXXXX was the result of a subscription by Canholdco for XXXXXXXXXX fully paid common shares of Acquisition Co. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

The Queen (92 DTC 6320), whether or not the income from a trust that is payable by the trust is taxable in the hands of an Indian who is a beneficiary under the trust, requires consideration of all factors connecting a particular category of property (including a right to income from a trust) to a location on or off the reserve. All relevant factors should then be analyzed and weighted against three considerations which are: (i) the purpose of the exemption from taxation under the Indian Act (see below), (ii) the nature of the property (benefit) and (iii) the nature of the taxation of the property. ... A determination of the relevant connecting factors to which the greatest weight can be given in a particular case can only be made after consideration of all the circumstances. ...