Search - consideration
Results 2281 - 2290 of 13696 for consideration
Ruling
2007 Ruling 2006-0194321R3 - Purchase of Target and Bump
The consideration for this transfer was paid in full by Bidco by the issuance to BuyerSubco III of common shares of Bidco. ... Bidco will subscribe for common shares of the capital stock of Newco II for a nominal cash consideration. 43. ... Bidco will transfer all of the common shares of the capital stock of Target to Newco I for FMV consideration. ...
Technical Interpretation - Internal
28 August 2007 Internal T.I. 2007-0236991I7 - B.C. Forest Revitalization Trust
The amounts could also be considered as an inducement for the purposes of paragraph 12(1)(x) as the contractor is obliged to release the licencee from any claims as consideration for the receipt of the amount. ... The terms of the Release make it clear that XXXXXXXXXX received the payment from the Trust in consideration for the reduction of the contract and in consideration for XXXXXXXXXX releasing each other from any claims in respect of this reduction. ... Consequently, it is arguable that the Lost Opportunity Amount represents an inducement for the purposes of paragraph 12(1)(x) as XXXXXXXXXX was obliged to act in a certain manner as consideration thereof. ...
Ruling
2005 Ruling 2005-0152251R3 - Interest Expense - Substituted Property
The Share Transfer Agreement provided for the transfer of the Transferred Shares for consideration equal to the fair market value of the Transferred Shares (the "Acquisition Price"). ... A Co and IF Co will enter into a share transfer agreement under which A Co will transfer XXXXXXXXXX% of the B Co Shares to IF Co for consideration equal to the fair market value of XXXXXXXXXX% of the B Co Shares. The consideration provided by IF Co will be common shares of IF Co with a fair market value equal to the fair market value of XXXXXXXXXX% of the B Co Shares. ...
Ruling
2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test
A note receivable from FinanceCo2 owed by Forsub1 for cash consideration of USD XXXXXXXXXX; b. A note receivable from Forco2 owed by ForGP for cash consideration of USD XXXXXXXXXX; and c. A note receivable from FinanceCo2 owed by Forsub2 for cash consideration of USD XXXXXXXXXX. 20. ...
Ruling
2096 Ruling 9606443 - BUTTERFLY
As consideration each Holdco will assume XXXXXXXXXX of the gross amount of XXXXXXXXXX debt and issue preferred shares as described in the following paragraphs. ... These shares will remain outstanding for the purposes of ownership of XXXXXXXXXX as a joint venture operator. 30) Each Holdco will redeem the Class XXXXXXXXXX shares issued to XXXXXXXXXX as consideration for the transfer of the assets\interest in assets. ... In consideration, XXXXXXXXXX will issue a promissory note to each Holdco in the amount of the purchase price of the said shares. ...
Ruling
2004 Ruling 2004-0080501R3 - Single-wing butterfly
As sole consideration for such transfer, Transferee will issue to A XXXXXXXXXX Common Shares and XXXXXXXXXX Class A Special Shares of Transferee having an aggregate FMV equal to the FMV of the shares of DC transferred by A to Transferee. ... In each case, the agreed amount will not exceed the FMV of the respective property, nor will it be less than the amount of any liabilities assumed by Transferee as consideration for the transfer of such property. 26. ... On the day following the redemption of the Class B Special Shares of Transferee described in paragraph 27 above, DC will purchase for cancellation and redeem all of the DC Common Shares and Preferred Shares owned by Transferee for FMV consideration. ...
Ruling
2001 Ruling 2001-0069213 - limited partnership; call option
Principal will acquire one Initial Limited Partnership Unit for consideration of $XXXXXXXXXX. General Partner will acquire one General Partnership Unit for consideration of $XXXXXXXXXX. 7. ... ParentCo will assign the Contract dated XXXXXXXXXX with the XXXXXXXXXX to SubCo for consideration that is common shares of SubCo. and ParentCo will elect under subsection 85(1) of the Act. ...
Ruling
2001 Ruling 2001-0097223 - REWARD POINTS
In consideration for the services for which ParentCo would be obligated (at the time when the Current Reward Points were earned) to provide to Institution Customers in the future, ParentCo received an up-front flat fee and recurrent fees from Institution based on the cost of a Current Reward Point. 5. ... As consideration, Partnership will assume liabilities related to the assets transferred and issue a promissory note in the amount of $XXXXXXXXXX, payable by Partnership to ParentCo in XXXXXXXXXX years with a fixed rate of return, and Partnership will issue additional limited partnership interests in the Partnership to ParentCo. ... Immediately thereafter, Institution will transfer its interest in the Partnership to NewCo in consideration for XXXXXXXXXX common shares which NewCo will issue from treasury. ...
Ruling
2002 Ruling 2001-0116073 - Certain Tax Consequences of buy/bump/sell
A GST election for nil consideration will be made by Target and Xco. 24. ... The consideration for the XXXXXXXXXX Assets will be cash and the assumption of the obligations related to customer and third party contracts forming part of the XXXXXXXXXX Assets and the consideration for the associated goodwill will be the issuance of one preferred share. ... Amalco intends to sell, for cash consideration, all of the issued shares of Xco (the "Xco Shares") and the Xco Debt to Finco. ...
Ruling
2003 Ruling 2002-0157683 - Split Up Butterfly
X and Y are therefore proposing to list this property for sale for cash consideration. ... Y will subscribe for XXXXXXXXXX Class A Common Shares of Yco for nominal consideration. 13. ... As consideration for the property so transferred, Yco will assume certain liabilities of Aco, and Aco will receive XXXXXXXXXX voting Class C Preferred Shares in the capital of Yco. ...