Search - consideration
Results 381 - 390 of 8021 for consideration
Ruling
30 November 1997 Ruling 9805113 - BUTTERFLY REORGANIZATION
On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $XXXXXXXXXX. 18. ... On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $XXXXXXXXXX. 19. ... On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $XXXXXXXXXX. 21. ...
Ruling
2001 Ruling 2000-0058363 - QSBC shares - 55(3)(a)
A will purchase the Loan from Holdco at its fair market value for cash consideration of $XXXXXXXXXX. 20. ... A will each transfer their XXXXXXXXXX common shares of Holdco to Newco, each in consideration of XXXXXXXXXX preferred shares of Newco. ... A will transfer at fair market value XXXXXXXXXX preferred shares of Holdco to Newco, in consideration for XXXXXXXXXX preferred shares of Newco. ...
Ruling
2001 Ruling 2001-0109813 F - PROPOSITION CONCORDATAIRE
Le XXXXXXXXXX, Opérante a émis XXXXXXXXXX actions catégorie " A " à Madame A pour une considération de XXXXXXXXXX $. 4. ... Le XXXXXXXXXX, Opérante a émis à Madame A XXXXXXXXXX actions de catégorie " C " pour une considération de XXXXXXXXXX $. 15. ... Le XXXXXXXXXX, Opérante a racheté les actions suivantes: Actions de catégorie " B " Nombre d'actions Considération Monsieur B XXXXXXXXXX XXXXXXXXXX $ Actions de catégorie " D " Nombre d'actions Considération Madame A XXXXXXXXXX XXXXXXXXXX $ Monsieur B XXXXXXXXXX XXXXXXXXXX $ 18. ...
Ruling
2007 Ruling 2006-0216551R3 - Interest Expense - Substituted Property
A Co issued to W Co a secured promissory note (the "Note") and additional common shares of A Co as consideration. ... The consideration provided by Finance Co was common shares of Finance Co with a fair market value equal to the fair market value of XXXXXXXXXX % of the B Co Shares. ... The consideration provided by US LLC for the B Co Shares will be the allocation of the initial member interest of US LLC with a fair market value equal to the fair market value of the B Co Shares. ...
Ruling
1999 Ruling 9829163 - RELATED GROUP LOSS UTILIZATION SCHEME
As consideration for the sale, XXXXXXXXXX Partnership will assume liabilities of XXXXXXXXXX Co. ... (c.1)(i) and (ii) and will not be less than the amount of non-share consideration received as consideration. 26. ...
Ruling
2005 Ruling 2005-0151921R3 - Butterfly Distribution
For greater certainty, the amount of any non-share consideration to be issued by each of Sibling1 Holdco, Sibling2 Holdco and Sibling3 Holdco as consideration for any DC1 Loss Properties received by the particular Sibling Holdco will not exceed the fair market value of such property so received. ... The amount of any non-share consideration to be allocated to any property that is not the subject of an election under subsection 85(1) will not exceed the fair market value of such property. ... For greater certainty, the amount of any non-share consideration to be issued by each of Sibling1 Holdco, Sibling2 Holdco and Sibling3 Holdco as consideration for any DC2 Loss Properties received by the particular Sibling Holdco will not exceed the fair market value of such property so received. ...
Ruling
2001 Ruling 2000-0034763 - Divisive Reorganization
In consideration, XXXXXXXXXX/Dco will issue to XXXXXXXXXX/Mrs. A XXXXXXXXXX preference shares. ... In consideration, XXXXXXXXXX/Eco will issue to XXXXXXXXXX/Mrs. B XXXXXXXXXX preference shares. ... In consideration, XXXXXXXXXX/Fco will issue to XXXXXXXXXX/Mr. C XXXXXXXXXX preference shares. ...
Technical Interpretation - Internal
13 July 2009 Internal T.I. 2009-0309291I7 - Deductibility of GST
The ETA contemplates the application of the GST based on the value of the consideration for a taxable supply. ... Therefore, it must be determined if the amount charged by the vendor represents consideration only (i.e., "tax-extra") or consideration and tax (i.e., "tax-included"). ... It is relevant to note that in this case, the vendor and purchaser would likely have treated the original billing as consideration without a GST component. ...
Ruling
30 November 1996 Ruling 9714643 - INTEREST DEDUCTIBILITY
The net proceeds to be received by XXXXXXXXXX from the issue XXXXXXXXXX is approximately $XXXXXXXXXX. 11.XXXXXXXXXX will use such net proceeds to acquire $XXXXXXXXXX shares and XXXXXXXXXX Series XXXXXXXXXX Notes of XXXXXXXXXX in consideration for $XXXXXXXXXX. ... XXXXXXXXXX 13.XXXXXXXXXX will acquire, at fair market value, all of the issued shares of XXXXXXXXXX and all the shares of XXXXXXXXXX not owned by XXXXXXXXXX in consideration for $XXXXXXXXXX. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Ruling
2001 Ruling 2001-0068223 - Adjusted cost base-shares acquired on merger
Principal Issues: Cost of shares acquired as a result of a foreign merger Position: Cost of shares includes an amount equal to the fair market value of the consideration given to acquire such shares. ... The "Consideration" is defined to include Canco common shares and a Note. ... The amount of the Note shall be $XXXXXXXXXX (U.S.) provided that such amount shall be reduced so as not to exceed XXXXXXXXXX% of the Consideration based upon the Closing Average Price of Canco common shares. ...