Search - consideration
Results 3091 - 3100 of 13706 for consideration
Ruling
2021 Ruling 2021-0882111R3 - Multing Wing Split Up Butterfly
DC will sell marketable securities with a fair market of approximately $XXXXXXXXXX to purchasers dealing at arm’s length with DC in exchange for cash consideration. ... The agreed amount in respect of each eligible property so transferred will not be greater than the FMV of such property, at the time of the transfer, nor will it be less than the FMV of the consideration therefor other than shares of the capital stock of the TC or a right to receive such shares. ... As sole consideration therefore, DC will issue to each such TC a non-interest bearing demand promissory note having a principal amount and FMV equal to the sum of the FMV of the common shares of DC held by such TC. ...
Ruling
2008 Ruling 2007-0251681R3 - Butterfly and freeze of an estate
The consideration on the rollover was XXXXXXXXXX Class A Special shares and XXXXXXXXXX class A common shares of Newco 1. ... As sole consideration for the property so transferred, Newco 3 will issue to the Mrs. ... As sole consideration for the shares so transferred, Newco 5 will issue to the Mrs. ...
Ruling
2014 Ruling 2012-0446701R3 - Butterfly reorganization
The class C preferred shares are redeemable and retractable at an amount equal to the consideration for which the shares were issued plus any unpaid cumulative dividend thereon. ... The class D preferred shares are redeemable at an amount equal to the consideration for which the shares were issued plus any unpaid cumulative dividend thereon. ... Immediately after the Estate Freeze, B and C respectively subscribed for XXXXXXXXXX Class A common shares in DC for a cash consideration of $XXXXXXXXXX. 16. ...
Ruling
2012 Ruling 2012-0439381R3 - Cross-border spin-off butterfly
As consideration for the demerger of DC Parent, Forco8 will receive shares of the capital stock of Foreign Spinco5. 41. ... As a result, the proceeds of disposition in respect of the DC Preferred Shares exchanged and the total cost to Foreign Pubco of the shares received as consideration for the DC Preferred Shares will be deemed to be equal to the ACB to Foreign Pubco of the DC Preferred Shares before the exchange (the cost of each class received as consideration for the DC Preferred Shares being determined according to paragraph 86(1)(b)). The proceeds of disposition in respect of the DC Common Shares exchanged and the total cost to Foreign Pubco of the shares received as consideration for the DC Common Shares will be deemed to be equal to the ACB to Foreign Pubco of the DC Common Shares before the exchange (the cost of each class received as consideration for the DC Common Shares being determined according to paragraph 86(1)(b)). ...
Ruling
2011 Ruling 2010-0388951R3 - Public Corporation Spin-Off
Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting of XXXXXXXXXX DC New Common Share and XXXXXXXXXX DC Butterfly Share. ... The agreed amount will be an amount equal to the greater of the cost amount of the Spin-off Property to DC and the fair market value of the non-share consideration, being the issuance of the Spinco Stock Options. ... Following completion of the Proposed Transactions, certain services will be provided by DC to Amalco for a transitional period in consideration for an arm's length management fee to be paid to DC. 44. ...
Ruling
2008 Ruling 2007-0240881R3 - 55(3)(b) Butterfly reorganization
X will receive no other consideration for such DC1 shares); and (e) Mrs. ... X will receive no other consideration for such shares of the Predecessor Corporations). ... X as described in Paragraphs 35(c) and (d) represent fair market value consideration for the transfers to Sibling1Co and Sibling2Co of Mrs. ...
Ruling
2008 Ruling 2007-0237501R3 - Public Corporation Spin-off
Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting of XXXXXXXXXX a DC New Common Share and XXXXXXXXXX a DC Butterfly Share. ... The agreed amount will be an amount equal to the greater of the cost amount of the Spin-off Property to DC and the fair market value of the non-share consideration, being the issuance of the Spinco Stock Options. ... Following completion of the Proposed Transactions, certain management services will be provided by DC to Amalco for a transitional period in consideration for an arm's length management fee to be paid to DC. ...
Ruling
2005 Ruling 2004-0088681R3 F - Split-up butterfly
Dans le cas des actions de catégorie "D" émises pour une considération en argent, la valeur de rachat correspond au montant de la considération. ... Dans le cas des actions de catégorie "F" émises pour une considération en argent, la valeur de rachat correspond au montant de la considération. ... N) Pourvu que le montant des Frais nets de location reportés de OPCO soit réduit du montant total de la Considération FNLR1 et de la Considération FNLR2, aucun montant afférent à ces considérations ne sera inclus dans le calcul du revenu de OPCO pour son année d'imposition dans laquelle auront lieu les transferts décrits au paragraphe 18 ci-dessus. ...
Ruling
2004 Ruling 2004-0096661R3 - 55(3)(a)
As consideration for the transfer, Hco issued common shares to Ico and a convertible note in the principal amount of $XXXXXXXXXX. ... Amalco 1 will purchase XXXXXXXXXX assets (XXXXXXXXXX) with a fair market value of $XXXXXXXXXX from Aco for cash consideration. ... In satisfaction of the consideration for the redemption, Amalco 1 will transfer to Dco the Aco Note 1 and the Aco Note 2. ...
Ruling
2000 Ruling 2000-0008403 - Public butterfly
During XXXXXXXXXX/ACO's XXXXXXXXXX fiscal year, XXXXXXXXXX options for common shares of XXXXXXXXXX/ACO were exercised under the stock option plan for total cash consideration of $XXXXXXXXXX. ... As consideration for the XXXXXXXXXX issued XXXXXXXXXX common shares in the capital of XXXXXXXXXX to the XXXXXXXXXX shareholders. ... No consideration will be given to any holder of the Old XXXXXXXXXX/ACO stock options in relation to such amendments. ...