Search - consideration
Results 2131 - 2140 of 13696 for consideration
Ruling
1998 Ruling 9823723 - BUTTERFLY TRANSFER
As sole consideration for such transfer, Holdco XXXXXXXXXX will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value at the time of the transfer of the shares transferred by XXXXXXXXXX to Holdco XXXXXXXXXX. ... In consideration for such transfers, each of Subco XXXXXXXXXX and Subco XXXXXXXXXX will issue Class A preferred shares and assume a portion of the liabilities of Amalco. ...
Ruling
1999 Ruling 9818193 - REORGANIZATION, ITAR, SUPERFICIAL LOSS
(b) At the same time as the transaction described above, XXXXXXXXXX will transfer, at fair market value, to XXXXXXXXXX all of her common shares of XXXXXXXXXX and, in consideration therefor, XXXXXXXXXX will receive XXXXXXXXXX common shares of XXXXXXXXXX. ... XXXXXXXXXX will sell the Adjusted Interest to XXXXXXXXXX at its fair market value in consideration for which XXXXXXXXXX will issue a non-interest-bearing promissory note payable at the rate of $XXXXXXXXXX per month to XXXXXXXXXX. ... The Class A shares to be issued to XXXXXXXXXX will be redeemed at an amount not greater than the value of the consideration for which the shares will be issued. 30. ...
Ruling
2018 Ruling 2018-0780201R3 - Post-mortem pipeline
Opco will transfer the Specified Properties to Subco in exchange for consideration consisting solely of XXXXXXXXXX common shares of Subco having a FMV equal to the aggregate FMV of the Specified Properties. ... As sole consideration for the redemption, Opco will issue the Opco Note to the Estate having a principal amount and FMV equal to the redemption amount and FMV of shares being redeemed, being $XXXXXXXXXX. ... The Estate will transfer its XXXXXXXXXX Opco Class B Special shares to Newco in exchange for consideration consisting of: a. ...
Conference
27 October 2020 CTF Roundtable Q. 3, 2020-0861031C6 - Safe income on reorganization
Opco then transferred Asset 2 to Newco in consideration for shares of Newco. ... Opco then transferred shares of Subco2 having an ACB of nil and a FMV of $500 to Newco in consideration for shares of Newco. ...
Ruling
2020 Ruling 2020-0860231R3 - Post-mortem planning
Class C, D, E and F preferred shares that are non-voting, redeemable, retractable, having a redemption amount equal to the FMV of the consideration received. ... For greater certainty, the sum of the principal amount of Note 2 and the PUC of the Class C preferred shares of Newco issued as consideration for the XXXXXXXXXX Class A common shares of Opco so transferred will not exceed the aggregate FMV of the XXXXXXXXXX Class A common shares owned by the Deceased immediately before the Deceased’s death. 20. ... Nothing in this letter should be construed as confirmation, express or implied, that, for the purposes of any of the rulings given above, any adjustment to the FMV of the properties transferred or the redemption amount of the shares issued as consideration, whether pursuant to a price adjustment clause or otherwise, will be effective retroactively to the time of the transfer and issuance of shares. ...
Ruling
2020 Ruling 2019-0833091R3 - Supplemental Ruling
On XXXXXXXXXX, CanLP 7 redeemed XXXXXXXXXX units owned by Cansub 4 in consideration for $XXXXXXXXXX, such amount being equal to the aggregate FMV of the units immediately before the redemption. ... On XXXXXXXXXX, Cansub 4 sold all its class D preferred shares of Cansub 3 to CanLP 11 in consideration for $XXXXXXXXXX, such amount being equal to the aggregate FMV of the Cansub 3 shares immediately before the sale. ... As consideration for the Distribution Property, TC ULC will: (a) assume certain liabilities (the TC ULC Assumed Liabilities) of DC ULC, including a portion of the Newco XXXXXXXXXX Loan (the Newco XXXXXXXXXX Assumed Loan). ...
Ruling
2022 Ruling 2022-0947921R3 - Post-mortem tax planning
Reasons: 1) Non-share consideration does not exceed the adjusted cost base of the transferred shares; 2) In accordance with the Act and consistent with CRA's published positions. ... In consideration for the redemption of the Class A special shares, Opco will issue PN1 to the Estate. ... The Estate will dispose of the Remaining Shares to Newco in consideration for PN2 and XXXXXXXXXX Class 1 common shares of the capital stock of Newco. ...
Ruling
2023 Ruling 2023-0969661R3 - Post-mortem Pipeline
Child 1 exchanged his XXXXXXXXXX Opco Class A Common Shares in consideration for XXXXXXXXXX Opco Class X Common Shares; b. Each of Child 2, Child 5, Child 6 and Child 7 exchanged their XXXXXXXXXX Opco Class A Common Shares in consideration for XXXXXXXXXX Opco Class Y Common Shares; c. ... All of the Opco Class Y Common Shares owned by each of the children’s holding corporations were redeemed in consideration for the Redemption Notes; and e. ...
Ruling
2024 Ruling 2023-0989031R3 - QET Internal Reorganization
(2) Is there an income inclusion as a result of a disposition of a QET interest where the only consideration for the disposition is an assumption of reclamation obligations? ... No amount will be separately received or earned by the Corporation in connection with the transfer of the QET Interest, for which the sole consideration will be the assumption of the Reclamation Obligations by the Partnership. 34. ... For greater certainty, the assumption of the Reclamation Obligations by the Partnership will not be considered additional consideration in respect of the transfer of the XXXXXXXXXX Assets by the Corporation to the Partnership. ...
Ruling
30 November 1996 Ruling 9629733 - BUTTERFLY RULING (XXXXXXXXXX)
On incorporation, Subco1 will issue to DC2 XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ... On incorporation, Parentco will issue to Mother XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ... On incorporation, Subco2 will issue to Parentco XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ...