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Ruling

2001 Ruling 2001-0082843 - Paragraph 55(3)(a) spin-off

The total consideration in respect of these purchases amounted to $XXXXXXXXXX. ... No other consideration will be received by Bco in respect of the conversion. 32. ... No other consideration will be received by Bco in respect of the conversion. 43. ...
Technical Interpretation - Internal

3 May 2001 Internal T.I. 2001-0081837 F - BILLET CONVERTIBLES PRINCIPAL

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. ...
Technical Interpretation - Internal

26 April 2001 Internal T.I. 2000-0046367 F - DEBENTURES CONVERTIBLES

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

2001 Ruling 2001-0091383 - internal reorganization

Upon incorporation, Subco issued 1 common share to DC in consideration of $XXXXXXXXXX. 16. ... No other consideration will be received by DC Shareholder in respect of the Share Exchange. ... As sole consideration for such transfer, Qco will issue XXXXXXXXXX Qco Preferred Shares to DC. ...
Ruling

2002 Ruling 2002-0178983 - REFINANCING

On incorporation, Canco # 10 issued XXXXXXXXXX common shares to Principal for aggregate consideration of $XXXXXXXXXX. ... The consideration was paid by Canco # 10 by the issuance of a note payable to Principal. ... Canco # 3 paid consideration of $XXXXXXXXXX (the "License Amendment Fee") to Canco # 2 as consideration for Canco# 2 agreeing to amend the License Agreement by issuance of a note. ...
Ruling

1999 Ruling 9910443 - SAFE-INCOME DETERMINATION TIME

In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX redeemable, retractable preference shares with a fair market value equal to the fair market value of the XXXXXXXXXX Shares at the time of the transfer. ... In consideration for the transfer, Subco will issue to XXXXXXXXXX the Subco Shares with a fair market value equal to the fair market value of the XXXXXXXXXX Shares at the time of the transfer. ... Subco will add an amount to the stated capital of the Subco Shares issued as consideration for the transfer of the XXXXXXXXXX Shares not to exceed the aggregate paid-up capital of the XXXXXXXXXX Shares. ...
Ruling

2008 Ruling 2008-0268041R3 - Purchase of Target and Bump

The consideration for this transfer was paid in full by Bidco by the issuance to BuyerSubco III of XXXXXXXXXX shares of Bidco. ... On XXXXXXXXXX, BuyerSubco III transferred all the shares of the capital stock of Bidco to Holdco II for FMV consideration. ... New Bidco will transfer all of the common shares of the capital stock of Target to Newco I for FMV consideration. ...
Ruling

2007 Ruling 2007-0227371R3 - Butterfly

Parent will transfer to TechCo, all of the DC TechCo Reorganization Shares held by Parent in consideration for the issuance by TechCo to Parent of XXXXXXXXXX TechCo Common Shares. ... The liabilities assumed as consideration for a property transferred pursuant to subsection 85(1) will not exceed the agreed amount in respect of that property. ...
Ruling

2003 Ruling 2003-0015553 - XXXXXXXXXX - Butterfly

The aggregate fair market value of all such consideration to be paid by each Newco to DC will be equal to the aggregate fair market value of the property transferred by DC to the particular Newco. ... The addition, under the BCA, to the stated capital account maintained for the Class D Shares that will be issued by each of Newco 1, Newco 2, Newco 3 and Newco 4, as the case may be, as consideration for the property transferred to the particular Newco by DC as described above, will not exceed the amount by which the aggregate of the agreed amounts in the particular Newco's subsection 85(1) election exceeds the aggregate of the fair market value of any non-share consideration paid by such Newco as consideration for such eligible property. ... (d) Each of Newco 1, Newco 2, Newco 3 and Newco 4 will receive DC lands in Proposed Transactions in areas subject to consideration for urban planning and development. ...
Miscellaneous severed letter

7 July 2005 Income Tax Severed Letter 2005-0117901R3 - Income trust reorganization

The purchase was made at fair market value for cash consideration and resulted in a taxable purchase and sale. ... The Partnership will redeem a portion of the LP Notes outstanding and held by the Fund and will issue additional LP Units to the Fund in consideration for such redemption. 31. ... The Fund will subscribe for one Trust Unit for $XXXXXXXXXX consideration. ...

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