Search - consideration
Results 3071 - 3080 of 13652 for consideration
Ruling
2010 Ruling 2009-0347041R3 - Loss Consolidation
On XXXXXXXXXX, Parent acquired, from arm's length parties, all the XXXXXXXXXX common shares of Holdings for consideration of approximately $XXXXXXXXXX. ... Newsubco issued XXXXXXXXXX common shares of its capital stock to Newparentco and XXXXXXXXXX shares to YCo, in each case for nominal consideration. 24. ... Lossco issued XXXXXXXXXX common shares of its capital stock to Amalco and XXXXXXXXXX shares to YCo, in each case for nominal consideration. 27. ...
Ruling
2009 Ruling 2007-0251621R3 - Split-Up Butterfly
The Voting Preferred Shares were issued to her on XXXXXXXXXX for consideration equal to their fair market value at that time. ... The increase to the PUC of the TC Common Shares that are issued as consideration for the Common Shares of DC transferred to each TC will not exceed the amount of PUC attributable to the Common Shares of DC for which such TC's Common Shares were issued. ... As consideration therefore, each TC will issue a non-interest bearing demand promissory note (the "TC Note") having a principal amount and FMV equal to the aggregate redemption amount of the TC Class A Preferred Shares. ...
Ruling
2007 Ruling 2006-0191631R3 - XXXXXXXXXX
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 plus the number of its Units as are held by designated beneficiaries in consideration for a cash payment of $XXXXXXXXXX per Class A Share (the "Class A Share Subscription Proceeds"). 11. ... No consideration other than Special Units and Units will be received by the Unitholders on the redemption of the Business Trust Special Units and Business Trust Units. 17. ... No consideration other than Special 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. 22. ...
Ruling
2005 Ruling 2005-0114861R3 - Butterfly - XXXXXXXXXX
The Newco Class C Shares, Newco Class D Shares and Newco Class E Shares will each have a redemption/retraction amount equal to the fair market value of the consideration for which such shares were issued and such amount will be subject to a price adjustment clause. ... For the purposes of the Act: the increase to the PUC of the XXXXXXXXXX Newco Class C Shares issued as consideration for the XXXXXXXXXX Class A Shares transferred to Newco by Sibling1 will not exceed the amount of PUC attributable to the Class A Shares for which the XXXXXXXXXX Newco Class C Shares were issued; and the increase to the PUC of the XXXXXXXXXX Newco Class D Shares issued as consideration for the XXXXXXXXXX Class A Shares transferred to Newco by Sibling1 Family Trust will not exceed the amount of PUC attributable to the Class A Shares for which the XXXXXXXXXX Newco Class D Shares were issued. 12. ... Newco will jointly elect with DC, in prescribed form and within the time limits referred to in subsection 85(6), to have the rules in subsection 85(1) apply to each transfer of eligible property that is included in the Transferred Assets and in respect of which Class E Shares of Newco have been issued as full or partial consideration therefore as described in Paragraph 14. ...
Ruling
2017 Ruling 2016-0643931R3 - PUC reinstatement on emigration
No consideration was paid by either Parent or Assignor for said assignment/assumption. ... A subscribed for XXXXXXXXXX class B common shares of Parent in consideration for an aggregate subscription price of XXXXXXXXXX (equivalent of $XXXXXXXXXX). ... All Target shares outstanding prior to the Amalgamation were cancelled without consideration or repayment of capital upon the Amalgamation. 27. ...
Ruling
30 November 1995 Ruling 9611353 F - REORGANISATION "SOMERSAULT"
XXXXXXXXXX 17.En date de l'incorporation, XXXXXXXXXX actions ordinaires furent souscrites par XXXXXXXXXX pour une considération totale de XXXXXXXXXX$. ... En date des présentes, Holdco a souscrit à XXXXXXXXXX actions de catégorie XXXXXXXXXX de XXXXXXXXXX pour une considération totale de XXXXXXXXXX$. ...
Ruling
2096 Ruling 9600253 - GROSS BASIS BUTTERFLY, FARM RESIDENCE, NISA
The consideration received will be cash or a promissory note payable on demand. ... The amount to be specified in respect of each of the class XXXXXXXXXX special shares will be equal to the fair market value of the property received by XXXXXXXXXX as consideration for such share. ... Pursuant to paragraph 88(2)(b) and subsection 84(2), but subject to (ii) to (iv) herein, each of XXXXXXXXXX will be deemed to have received a dividend (the "winding-up dividend") on its common shares of XXXXXXXXXX equal to the proportion of the amount by which the aggregate fair market value of the property of XXXXXXXXXX distributed by XXXXXXXXXX as the case may be, on its winding-up as consideration for the cancellation of its common shares, exceeds the paid-up capital of such shares, that the number of shares held by each of XXXXXXXXXX is of the number of shares of that class that are cancelled. ...
Ruling
2004 Ruling 2003-0047911R3 - XXXXXXXXXX - 55(3)(a)
As sole consideration therefor, Leasing will issue XXXXXXXXXX Class C shares to Opco 1 having an aggregate fair market value equal to the aggregate fair market value of the Opco 1 Assets. ... As sole consideration therefor, Leasing will issue XXXXXXXXXX Class E Shares to Holdco having an aggregate fair market value equal to the aggregate fair market value of the XXXXXXXXXX New Opco 1 Preferred Shares. ... As consideration therefor, Opco 1 will issue to Leasing a demand non-interest bearing promissory note (the "Opco 1 Note") with a principal amount and fair market value equal to the redemption amount. ...
Ruling
2004 Ruling 2003-0053881R3 - Butterfly Ruling - XXXXXXXXXX .
Parent acquired his XXXXXXXXXX Class B Shares and XXXXXXXXXX Class C Shares of DC on XXXXXXXXXX for cash consideration of $XXXXXXXXXX per share. Parent acquired his XXXXXXXXXX Class A- Series 1 of DC on XXXXXXXXXX as consideration for his transfer of shares of a predecessor corporation of Xco to DC in respect of which a joint election was filed pursuant to section 85. ... As consideration, each of TC 1 and TC 2, as the case may be, will issue a non-interest bearing demand promissory note (the "TC 1 Note" and the "TC 2 Note" respectively), in favour of DC, having a principal amount equal to the aggregate redemption amount of its TC Special Shares that it issued to DC as described in Paragraph 14 above. ...
Ruling
2004 Ruling 2004-0093101R3 - Butterfly - Family Farm Corporation
For greater certainty, the agreed amount for the purposes of each such election will not be less than the FMV of the particular property or the amount of any non-share consideration received by Distributorco as consideration for such property. ... On the day immediately following the completion of the Proposed Transactions, Transferee will sell its portion of the interest in the farmland described as XXXXXXXXXX to Distributorco for consideration equal to the FMV of such farmland. As consideration for such property, Distributorco will issue an note that will be due and payable upon the passing of Shareholder 1 and which will bear interest at the prescribed rate that is in effect on the date that particular transfer of the farmland takes place. ...