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Royalties are defined in paragraph 4 of Article 12 of the Treaty: The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including computer software, cinematograph films, or films or tapes or discs or other means of reproduction used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. ... Paragraph 11.6 of the OECD commentary to Article 12, concerning the taxation of royalties, states: The appropriate course to take with a mixed contract is, in principle, to break down, on the basis of the information contained in the contract or by means of a reasonable apportionment, the whole amount of the stipulated consideration according to the various parts of what is being provided under the contract, and then to apply to each part of it so determined the taxation treatment proper thereto. If, however, one part of what is being provided constitutes by far the principal purpose of the contract and the other parts stipulated therein are only of an ancillary and largely unimportant character, then the treatment applicable to the principal part should generally be applied to the whole amount of the consideration. ...

In the course of such an estate freeze, the freezor exchanges his participating and voting shares in consideration for preferred shares having a redemption price equal to the value of the participating shares before the exchange. ... Class B shares: non-participating, non-voting, redeemable at the option of the holder at a redemption price equal to the consideration received by the corporation at the time of their issuance and entitled to an annual dividend of a maximum of 6%. Class C shares: non-participating, voting, redeemable at the option of the holder at a redemption price equal to the consideration received by the corporation at the time of their issuance and entitled to an annual dividend of a maximum of 6%, Class D shares: non-participating, voting and redeemable by the corporation at a price equal to the paid-up capital for such shares. ...

Acquisitionco CAN would then acquire all of the issued and outstanding shares of the capital-stock of Canco for cash consideration. ... Y, wants to acquire all of the shares of USco owned by Canco for cash consideration. ... Furthermore, the shares of the capital stock of Purchaseco US would not be received as consideration for the acquisition of shares of the capital stock of Canco by Purchaseco US or by Purchaseco Can. ...

DC will subscribe for common shares of Newco for nominal consideration. Foreignco will subscribe for redeemable preferred shares of Newco for nominal consideration. ... Foreignco will receive additional redeemable preferred shares of Newco as the sole consideration for the shares of NRCO #1 and NRCO #2 transferred by it to Newco. ...

Among other things, an "exempt amount" includes an amount of trust income paid in a particular year (or within 60 days of the end of the trust's taxation year) by a trust created before October 30, 2003 directly to a beneficiary, as determined without reference to subsection 248(25), of that trust where the beneficiary is a natural person and acquired no portion of his or her interest in the trust for consideration, the amount was not included in computing an "exempt amount" for any other taxation year and no "contribution" has been made to the trust on or after July 18, 2005. ... The payment of a bill or invoice of the deemed resident trust by a beneficiary for no consideration would constitute a "contribution" as defined in proposed subsection 94(1). ... Thus, the payment of an invoice by a beneficiary without any consideration received in return would constitute a "contribution" as defined in proposed subsection 94(1) such that the payment of such an invoice in such circumstances at any time after July 17, 2005 would cause each subsequent distribution of trust income (other than an amount that is taxed in the trust by reason of paragraph 104(7.01)(b)) to lose its status as an "exempt amount" as defined in proposed subsection 94(1). ...

À titre de considération, NOUCO a émis en faveur de SOPE des actions ordinaires de son capital-actions et un billet à payer à SOPE, et a pris en charge les dettes de l'entreprise de SOPE autres que les dettes qui se rattachaient aux biens qui n'ont pas été transférés à NOUCO. ... À titre de considération, NOUCO a émis en faveur de SOPE des actions ordinaires de son capital-actions et un billet à payer à SOPE, et a pris en charge toutes les dettes de l'entreprise de SOPE. ... À titre de considération, NOUCO a émis des actions ordinaires de son capital-actions et un billet à payer, et a pris en charge toutes les dettes de l'entreprise de SOPE. ...

Corporation A then permits Corporation B to broadcast the artistic events in Canada in consideration of the payment of money the amount of which depends on the income this broadcasting will generate to Corporation B. a) Is the CRA of the opinion that subparagraph 212(1)(d)(i) and/or (vi) of the ITA would apply to payments made by Corporation B to Corporation A? ... The legislative proposals of July 18, 2005, contains a proposed amendment to paragraph 212(1)(d) to add an exclusion to paragraph 212(1)(d) when a payment is an amount to which subsection 212(5) would apply if that subsection were read without reference to "to the extent that the amount relates to that use or reproduction" (as amended by the legislative proposals of July 18, 2005). c) Paragraph 4 of Article XII of the Canada-US Tax Convention (1980) (hereinafter called the "Convention") defines the term "royalties" used in Article XII as being payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic, or scientific work (including motion pictures and work on film, videotape or other means of reproduction for use in connection with television). If we take into consideration the assumption put forward about the characterization of the payments Corporation B had made, these payments would be considered as royalties for the purpose of Article XII of the Convention. ...

A à titre de considération, en raison des caractéristiques des 100 actions privilégiées de catégorie "A" autres que le montant (1 million $) attribué à titre de valeur de rachat, M. ... A, pour une considération de 100 $. 11. Suite à une vérification, l'ARC conclurait que la JVM des 200 actions privilégiées de catégorie "A" du capital-actions de OPCO est inférieure à leur valeur de rachat de 1 million $. 12. ... Le bulletin d'interprétation IT-169 existe depuis longtemps (daté du 6 août 1974) et ne prend pas en considération tous les types de clauses de rajustement du prix, ni toutes les situations où des clauses de rajustement du prix sont habituellement utilisées. ...

As the interests in these two unincorporated joint ventures represent an interest in the underlying assets and liabilities of those joint ventures, the consideration will be defined by way of the following formula: The proportionate interest in the undivided interest in the liabilities of the joint ventures (i.e. ... The excess of the fair market value of the joint ventures over the consideration issued in the previous two components will be added to the Limited Partner's capital otherwise belonging to the First Nation. ... Ruling Given Provided that the preceding statements constitute a complete and accurate disclosure of all of the relevant facts, proposed transactions and purpose of the proposed transactions, we rule as follows: Because the First Nation is a public body performing a function of government in Canada within the meaning of paragraph 149(1)(c) of the Act, and therefore exempt from tax under Part I of the Act, no tax will be payable under Part I by the First Nation on any amounts included in its income as a result of the transactions described above, which, for greater certainty, may include income allocated from the Limited Partnership, dividends from the General Partner or consideration received from the Limited Partnership for the First Nation's interests in JV#1 and JV#2. ...

In consideration for such transfer, Newco will issue a number of common shares to XXXXXXXXXX and assume certain liabilities of XXXXXXXXXX. 23.XXXXXXXXXX and Newco will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer of each property of XXXXXXXXXX, other than the accounts receivable relating to the business of the XXXXXXXXXX division, that is an eligible property transferred to Newco. ... Paragraph 85(1)(h) will apply to deem that the cost to XXXXXXXXXX of the Newco shares received as consideration for the transfer described in paragraph 22 above will be the aggregate of the agreed amounts in respect of each eligible property transferred less the fair market value at the time of the transfer of any consideration other than such shares. ...