Search - consideration

Results 2141 - 2150 of 13696 for consideration
Ruling

2003 Ruling 2003-0022393 - Split Up Butterfly

DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee1 for fair market value consideration. ... DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee2 for fair market value consideration. ... DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee3 for fair market value consideration. ...
Ruling

2020 Ruling 2020-0844991R3 - Internal Reorganization - 55(3)(a)

GP’s Articles will also be amended to add Class C1 shares, which will be voting shares that are redeemable for the consideration for which they were issued. ... In accordance with subsection 51(1), D will exchange the XXXXXXXXXX Class B shares that he holds in GP in consideration for XXXXXXXXXX Class C1 shares in GP having an aggregate PUC, ACB and FMV of $XXXXXXXXXX. ... D and A or the family trust in favor of A will subscribe for the ManagementCo shares in consideration for a nominal cash consideration. 57. ...
Ruling

2010 Ruling 2009-0332571R3 - Loss consolidation - related or affiliated

As sole consideration, HASub issued Class F preferred shares to each of Mr. ... As sole consideration, HBSub issued Class F preferred shares to each of Mr. ... (b) An unlimited number of Preferred Shares2 that are non-voting, non-participating, redeemable and retractable at any time at the request of the holder for an amount equal to the fair value of the consideration received upon issuance. ...
Ruling

2015 Ruling 2013-0490651R3 - Single-wing Split-up Farm Butterfly

Sibling1 will transfer all of his shares of DC to TC and, as consideration therefor, Sibling1 will receive XXXXXXXXXX Class G preferred shares of TC with an aggregate fair market value equal to the aggregate fair market value, at the time of the transfer, of the DC shares transferred by Sibling1 to TC. ... As consideration therefor, TC will issue to DC Promissory Note1. DC will accept Promissory Note1 as full payment for the aggregate redemption amount of the TC Preferred Share so redeemed. 22. ... As consideration therefor, DC will issue to TC Promissory Note2. TC will accept Promissory Note2 as full payment for the aggregate fair market value of the common shares. 23. ...
Ruling

2015 Ruling 2014-0554231R3 - Split-up Butterfly

Each share will be entitled to a non-cumulative preferential dividend of XXXXXXXXXX of XXXXXXXXXX percent (XXXXXXXXXX%) of the amount of the consideration for which the share was issued. Upon a liquidation of the corporation, the share will be entitled to the consideration for which the share was issued. Each share will be redeemable and retractable for the consideration for which the share was issued (the "Class E shares"). 13. ...
Ruling

2012 Ruling 2012-0440021R3 - Standard split-up butterfly

Sibling2 will purchase the personal residence from DC for fair market value consideration. 12. Sibling2 will purchase the shares of Gasco owned by Sibling1 for fair market value consideration. 13. ... TC1 will sell to TC2, within XXXXXXXXXX days following the completion of the Proposed Transactions described above, its XXXXXXXXXX% interest in the XXXXXXXXXX for fair market value consideration. ...
Ruling

2006 Ruling 2006-0190371R3 - Reorganization of a mutual fund trust - s. 132.2

The Fund will subscribe for one GPCo Common Share, the consideration for which will be $XXXXXXXXXX cash. 15. ... (b) The MFC Class A Shares will, subject to the XXXXXXXXXX: (i) be non-voting shares; (ii) entitle the holder thereof to dividends, as and when declared by the board of directors; (iii) be redeemable at the option of the holder for a redemption price equal to the fair market value of any consideration paid to subscribe for the share on issuance, which redemption price will be payable in cash or satisfied by the transfer of Fund Units; (iv) entitle the holder, without taking further action, to receive the redemption price upon receipt by MFC of a MFC Class A Share; (v) under no circumstances may MFC suspend redemption of a MFC Class A Share; and (vi) on the dissolution of MFC, entitle the holder thereof to the redemption price in preference to any distribution on the MFC Common Shares. ... The Fund will subscribe for one MFC Common Share, the consideration for which will be a cash payment of $XXXXXXXXXX. 19. ...
Ruling

2006 Ruling 2006-0199751R3 - Income Trust Reorganization

The Fund will subscribe for that number of Class A Shares of Newco as is equal to the number of its issued and outstanding Units in consideration for a cash payment estimated at $XXXXXXXXXX per Class A Share (the "Class A Share Subscription Proceeds"). ... No consideration other than Units will be received by the Unitholders on the redemption of the Class A Shares and no consideration other than Units will be received by the Fund on the redemption of the Class B Shares. 30. ... For greater certainty: (i) in respect of each of the Amalco Properties, Amalco's proceeds of disposition of the particular property and the Fund's cost in respect of the property will be determined under paragraph 132.2(1)(c) to be the lesser of the fair market value of the property and the cost amount to Amalco of the property (if the amount agreed upon in respect of the property in the election is not greater than the cost amount); (ii) Amalco's aggregate cost of the Units received by it from the Fund as consideration for the disposition of the Amalco properties will be deemed to be nil, pursuant to subparagraph 132.2(1)(h)(i); (iii) Amalco's aggregate proceeds of disposition of the Units distributed to Unitholders and to the Fund pursuant to the redemptions described in paragraph 28 will be deemed to be nil, pursuant to paragraph 132.2(1)(l)(i); (iv) the proceeds of disposition to a Unitholder of a Class A Share redeemed by Amalco as described in paragraph 28, and the cost to the Unitholder of Units received as consideration for the redemption, will be deemed, pursuant to paragraph 132.2(1)(j), to be equal to the cost amount to the Unitholder of the Class A Share immediately before the Asset Transfer Time; (v) paragraph 132.2(1)(j) will apply on the redemption by Amalco of the Class B Shares held by the Fund in consideration for Units as described in paragraph 28, such that the proceeds of disposition to the Fund of the Class B Shares will be deemed, pursuant to paragraph 132.2(1)(j), to be equal to the cost amount to the Fund of the Class B Shares immediately before Asset Transfer Time, and the Fund will therefore not recognize any income, gain or loss solely as a result of the redemption of the Class B Shares; (vi) pursuant to subsection 131(4) and subparagraph 132.2(1)(o)(i), section 84 will not apply to deem a dividend to be paid by Amalco nor to deem a dividend to be received by any shareholders of Amalco. ...
Ruling

2006 Ruling 2006-0172931R3 - income trust reorganization

Holdco will transfer all its limited partnership interest in Holdings LP to Holdco II in consideration for common shares of Holdco II having a fair market value equal to that of the transferred limited partnership interest, and will cease to be a partner of Holdings LP. ... Amalco MFC and the Fund intend to enter into an agreement of purchase and sale under which Amalco MFC will transfer all of its assets to the Fund in consideration for the Fund assuming its indebtedness, if any, and in consideration for the Fund issuing to Amalco MFC a number of Fund Units with an aggregate fair market value equal to the fair market value of the assets so transferred less the amount of assumed liabilities, if any. ... This will be the only consideration received on the redemption of the Amalco Class A and Amalco Class B shares. ...
Ruling

2005 Ruling 2005-0142491R3 - Split-up butterfly

Aco will file Articles of Amendments to convert the existing authorized, unissued, non-voting Class "D" shares into voting shares which will be redeemable by Aco for an amount equal to the FMV of the amount received by Aco as consideration for the share. 23. ... None of the Class "A" or Class "D" shares will be issued for consideration that includes a taxable preferred share. 33. ... For greater certainty, the agreed amount for any capital property included in the subsection 85(1) election, referred to herein, will not be less than the amount of any liabilities assumed as consideration therefore, and will not exceed the fair market value of each such property. ...

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