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Results 3571 - 3580 of 13709 for consideration
Ruling

2013 Ruling 2013-0492731R3 - qualifying disposition -mutual fund trust

The Fund will subscribe for MFT Units for a nominal cash consideration. ... No consideration other than the Fund Units will be received by the Fund and the Fund Unitholders on the redemption of the MFT Units. 36. ... The one MFT Unit held by the Fund will be cancelled for no consideration. ...
Ruling

2014 Ruling 2013-0516071R3 - Reorganization

The Lossco Preferred Shares will be redeemable and retractable for an amount per share (the "Lossco Preferred Share Redemption Amount") equal to the result obtained when the fair market value of any property transferred to Lossco as consideration for the Lossco Preferred Shares on the date of first issuance of the Lossco Preferred Shares less the amount of any non-share consideration paid, assumed or delivered by Lossco for the acquisition of such property is divided by the number of Lossco Preferred Shares issued as consideration therefor. ... The Profitco Preferred Shares will be redeemable and retractable for an amount per share (the "Profitco Preferred Share Redemption Amount") equal to the result obtained when the fair market value of any property transferred to Profitco as consideration for the Profitco Preferred Shares on the date of first issuance of the Profitco Preferred Shares less the amount of any non-share consideration paid, assumed or delivered by Profitco for the acquisition of such property is divided by the number of Profitco Preferred Shares issued as consideration therefor. ...
Ruling

2015 Ruling 2015-0606721R3 - Post Mortem Hybrid/Partial Pipeline Planning

In consideration of the redemption of the Redeemed RDTOH Shares, the Corporation will issue to the Estate PN1. ... In consideration of the redemption of the Redeemed CDA Shares, the Corporation will issue to the Estate PN2. ... The Estate will transfer the Remaining Shares to Newco in consideration for PN3 and XXXXXXXXXX Class B shares of the capital stock of Newco. ...
Ruling

2010 Ruling 2010-0375301R3 - Loss Utilization and reorganization

Parent will subscribe for one Acquisico Common Share for nominal consideration. 25. ... Acquisico will reduce the stated capital of the Acquisico Common Share and Acquisico Preferred Shares to $XXXXXXXXXX per class, without consideration. 32. ... Opco will subscribe for Newco Common Shares for nominal consideration. 37. ...
Ruling

2011 Ruling 2011-0409641R3 - Internal Reorganisation - 55(3)(a) and (b)

On the same day, XXXXXXXXXX Trust subscribed to XXXXXXXXXX common shares of the capital stock of Holdco in consideration for $XXXXXXXXXX. ... PROPOSED TRANSACTIONS 8) Holdco will redeem successively XXXXXXXXXX Class D shares of its capital stock for a cash consideration of $XXXXXXXXXX and XXXXXXXXXX Class D shares of its capital stock for a cash consideration of $XXXXXXXXXX. ... After the redemption of the Class D preferred shares of the capital stock of Holdco, the only type of assets of Familyco will be "cash and near-cash". 9) Child I will transfer all of his Class A common shares and Class E preferred shares of the capital stock of Familyco to Childco I in consideration for the issuance by Childco I of a number of common shares with a FMV equal to the FMV of the Class A common shares and the Class E preferred shares of the capital stock of Familyco transferred. ...
Ruling

2010 Ruling 2008-0303431R3 - Merger of fee simple and leasehold interests

The original Sublessee made improvements to the subleased property which involved the construction of a XXXXXXXXXX project and assigned its interest in the Sublease to Sublessee #1 in consideration for $XXXXXXXXXX in XXXXXXXXXX. ... The original Sublessee made improvements to the subleased property which involved the construction of a XXXXXXXXXX project and assigned its interest in the Sublease to Sublessee #2 in consideration for $XXXXXXXXXX in XXXXXXXXXX. ... The cost of the Subleased Property to Sublessee #2 will be the consideration given by Sublessee #2 to acquire the fee simple interest in its Subleased Property as described in Paragraph 17. ...
Ruling

2009 Ruling 2009-0344191R3 - Loss Consolidation

Newco will issue common shares of its capital stock to Holdco for nominal consideration. 10. ... Lossco 1 will issue common shares of its capital stock to Holdco for nominal consideration. 12. ... Lossco 2 will issue common shares of its capital stock to Holdco for nominal consideration. 14. ...
Ruling

2007 Ruling 2007-0232261R3 - Post butterfly transaction

On incorporation, TC3 will subscribe for at least one Common Share of TC3 Subco for nominal consideration. ... As sole consideration for the transfer of the Investco Shares to TC3 Subco, TC3 Subco will issue XXXXXXXXXX Common Shares to TC3. 24. ... (h) Other than the share consideration described above, no other consideration will be received by any shareholder of a predecessor corporation as a consequence of the amalgamation. ...
Ruling

2007 Ruling 2007-0230761R3 - 55(3)(a) - stock dividend - sale to non-resident

As consideration for the transfer, Spinco will issue XXXXXXXXXX common shares. ... As consideration for the transfer, Spinco will issue XXXXXXXXXX Spinco Class A Shares. ... Holdco1 intends to transfer all of the shares of Holdco2 to TiercoB for cash consideration equal to the FMV of the shares of Holdco2. 24. ...
Ruling

2006 Ruling 2006-0192521R3 - Loss Utilization

Profitco and Newco will enter into a PSA pursuant to which Profitco will agree to transfer the Portfolio to Newco for consideration consisting of Newco Preferred Shares. ... As sole consideration therefor, Newco will issue to Profitco a number of Newco Preferred Shares having an aggregate fair market value and an aggregate redemption amount equal to the fair market value of the Portfolio. ... Lossco and Profitco will enter into an agreement providing, inter alia, for the transfer of the Portfolio by Lossco to Profitco in consideration for the repayment of the Newco Demand Loan. ...

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