Search - consideration
Results 2151 - 2160 of 13696 for consideration
Ruling
2018 Ruling 2017-0714411R3 - Butterfly Reorganization
As consideration for the transfer, TC will issue to Child 2 XXXXXXXXXX TC Common Shares. ... As consideration for the transfer, TC will issue to Mother XXXXXXXXXX TC Class A Shares. ... As consideration for the transfer, TC will issue a non-interest bearing demand promissory note in the principal amount equal to the FMV of the policy (the “TC Insurance Note 2). ...
Ruling
2004 Ruling 2003-0053731R3 - Gross Asset Butterfly
On that same day, Sibling 1 subscribed for XXXXXXXXXX newly authorized Class B Shares and Sibling 2 subscribed for XXXXXXXXXX newly authorized Class C Shares for fair market value consideration. ... The authorized share capital of Sibling 1 Co and Sibling 2 Co will include voting common shares and voting preferred shares, redeemable and retractable for an amount equal to the fair market value of the consideration for which such shares are issued. Sibling 1 will subscribe for XXXXXXXXXX common shares of Sibling 1 Co for an aggregate consideration of $XXXXXXXXXX and Sibling 2 will subscribe for XXXXXXXXXX common shares of Sibling 2 Co for an aggregate consideration of $XXXXXXXXXX. 11. ...
Ruling
2001 Ruling 2000-0050983 - Re-freeze transactions
B Holdco for consideration consisting solely of XXXXXXXXXX Class A common shares of Mrs. ... B Holdco for consideration consisting solely of XXXXXXXXXX Class A common shares of Mr. ... B Holdco for consideration consisting solely of XXXXXXXXXX Class B common shares of Mr. ...
Ruling
1999 Ruling 1999-9914603 - Interest deductibility
LP will advance $XXXXXXXXXX to LPSub in consideration for a promissory note (the "LP Note"). ... LPSub will advance $XXXXXXXXXX to BCO in consideration for a promissory note (the "LPSub Note"). ... In consideration for the deletion of the Option clause in the Contract, the PARTNERSHIP will pay XXXXXXXXXX in cash using the proceeds of the BCO capital contribution. ...
Ruling
2002 Ruling 2001-0083623 - XXXXXXXXXX
The amount that each Holdco will add to its stated capital account in respect of its Holdco Class B Shares under the BCA will equal the aggregate PUC attributable to the Investco Class B Shares it will receive from Parent as consideration for such shares. The amount that each Holdco will add to its stated capital account in respect of its Holdco Class D Shares under the BCA will equal the aggregate PUC attributable to the Investco Class D shares it will receive from Parent as consideration for such shares. 11. ... As sole consideration therefore, Holdco A will issue XXXXXXXXXX Holdco A Common Shares to the Child A Family Trust having an aggregate FMV equal to the FMV of the Common Shares of Investco so received. ...
Ruling
1999 Ruling 9923993 - REORGANIZATION
This would be required in the course of the intended reorganization since on Aco's acquisition of DC's assets, Aco would issue shares to DC as partial consideration. ... The principal amount of any DC liability assumed in part consideration for a transferred property will not exceed its agreed amount. 26. ... The principal amount of any Aco liability assumed in part consideration for a transferred property will not exceed its agreed amount. 38. ...
Ruling
2000 Ruling 1999-0012953 - Butterfly; Classfication of Property
As sole consideration for such transfer, Asub will issue to Aco XXXXXXXXXX Common shares of its capital stock. ... As sole consideration for such transfer, Bsub will issue to Bco XXXXXXXXXX Common shares of its capital stock. ... As sole consideration for such transfer, Csub will issue to Cco XXXXXXXXXX Common shares of its capital stock. ...
Ruling
2021 Ruling 2020-0874961R3 - 55(3)(a) Internal Reorganization
As sole consideration for the transfer, Child 1 will receive XXXXXXXXXX Class A common shares of TC1 having an aggregate FMV equal to the FMV of the DC shares so transferred. ... As sole consideration for the transfer, Child 2 will receive XXXXXXXXXX Class A common shares of TC2 having an aggregate FMV equal to the FMV of the DC shares so transferred. ... As sole consideration for the transfer, Child 3 will receive XXXXXXXXXX Class A common shares of TC3 having an aggregate FMV equal to the FMV of the DC shares so transferred. ...
Technical Interpretation - External
17 February 2012 External T.I. 2011-0428561E5 - 88(1)(c)(vi) Bump Denial Rule
As consideration for these transfers, each of A, B and C receives a promissory note and common or preferred shares of the capital stock of NEWCO. ... If C does not participate in incorporating NEWCO and sells his shares of the capital stock of HOLDCO to A and B at FMV in consideration for cash before the transfer of the shares of HOLDCO to NEWCO, could NEWCO bump the cost of eligible property received from HOLDCO on its winding-up, as C would not receive any of HOLDCO's property? ... However, for the purposes of subparagraph 88(1)(c)(vi), if C receives from A and B property other than property distributed by HOLDCO to NEWCO or substituted property as consideration for the sale of his shares of the capital stock of HOLDCO then the bump denial rule in subparagraph 88(1)(c)(vi) should not be applicable in the Particular Situation. ...
Ruling
2012 Ruling 2012-0435291R3 - Public Corporation PUC Reduction
The Corporation transferred the Properties to Newco and received, as consideration, common shares of Newco. ... On XXXXXXXXXX, the Corporation sold the common shares of Newco to PurchaseCo at fair market value and, as consideration, PurchaseCo issued XXXXXXXXXX common shares and XXXXXXXXXX special warrants to the Corporation. ... The Corporation will hold an annual general meeting at which time its shareholders will be asked to approve a reduction of the stated capital of its common shares in accordance with the Canada Business Corporations Act, consideration for which will be paid by way of distribution of XXXXXXXXXX common shares of PurchaseCo (pro-rata to the shareholdings of the Corporation). 11. ...