Search - consideration

As consideration for the property transferred by DC to TC1 and TC2, each of TC1 and TC2 will: (a) assume such of DC's liabilities, if any, as are specifically secured by assets received by TC1 or TC2, respectively; (b) assume all amounts payable, if any, from DC to, in respect of TC1, Mr. ... The amount to be specified in respect of each of such share will be expressed as a dollar amount (and not expressed as a formula), will not be subject to change thereafter, and will be equal to the FMV of the consideration for which each TC1 Class B Preferred Shares and the TC2 Class B Preferred Share is issued. 64. ... As consideration therefore, TC1 will issue TC1 Redemption Note and TC2 will issue TC2 Redemption Note, having a principal amount and FMV equal to the aggregate redemption amount and FMV of the preferred shares so redeemed. ...

An unlimited number of Class A, B, and C, non-voting special shares, redeemable and retractable for the FMV of the consideration received upon issuance (subject to a price adjustment clause); d. ...

On incorporation, GC1 will subscribe for XXXXXXXXXX TC Common Share for cash consideration of $XXXXXXXXXX. 20. ... On incorporation, GC2 will subscribe for XXXXXXXXXX TC Common Share for cash consideration of $XXXXXXXXXX. 21. ... On incorporation, GC3 will subscribe for XXXXXXXXXX TC Common Share for cash consideration of $XXXXXXXXXX. 22. ...

Sibling1 will sell his Sibling1 TC Common Shares to New Sibling1 Trust in exchange for nominal consideration. 64. ... DC Amalco will subscribe for XXXXXXXXXX ReserveCo Common Share for nominal consideration. ... DC Amalco will subscribe for XXXXXXXXXX InsuranceCo Common Share for nominal consideration. ...

Former Canco also assigned certain XXXXXXXXXX trade-marks to a subsidiary of Canco 3 for nominal consideration. 82. ... On incorporation, Pubco 2 Group Newco issued XXXXXXXXXX ordinary share to Forco 11 for nominal cash consideration and issued XXXXXXXXXX share to Foreign Pubco 2 for nominal cash consideration. ... On incorporation, ServiceCo issued XXXXXXXXXX ordinary share to Forco 11 for nominal cash consideration and issued XXXXXXXXXX share to Foreign Pubco 2 for nominal cash consideration. ...

DC2 will receive FMV consideration from SpinCo Sub in the form of one SpinCo Sub Common Share for every transferred New DC1 Special Share. ... Every Participant will receive FMV consideration from SpinCo in the form of one SpinCo Common Share for every transferred New DC2 Special Share. ... DC2 will transfer to SpinCo all of the SpinCo Sub Common Shares that it holds in consideration for SpinCo Special Shares (the “DC2 Distribution”). ...

It is therefore the legal character of amounts that determines their Part I.3 tax treatment although we recognize that accounting terminology must be given consideration in this regard. ...

Please send any additional information concerning this matter to XXXXXXXXXX at the XXXXXXXXXX Tax Centre for further consideration. ...

Flaherty, Minister of Finance, for his consideration. I trust that the information I have provided clarifies the CRA’s position on this matter. ...

This loss may be denied pursuant to subparagraph 40(2)(g)(ii) of the Act unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...