Search - consideration

Holdco acquired those Subco shares from Individual B and his siblings by issuing its shares to each of them as consideration. ... In XXXXXXXXXX, Trust1 purchased all of the Subject Shares from Individual A for cash consideration of $XXXXXXXXXX. ... The aggregate FMV of the consideration paid by Bco for the Particular Shares will equal the aggregate FMV of the Particular Shares transferred to Bco. ...

The preferred shares will have no par value, will be non-voting and will be redeemable and retractable for an amount equal to the fair market value of the consideration received by the company on the issue of the shares. ... No other consideration will be received by XXXXXXXXXX in respect of this transaction. ... Other than the settlement and cancellation of the Note, there will be no consideration paid by XXXXXXXXXX for the Option. ...

In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX a number of common shares equal to the number of XXXXXXXXXX common shares held by Holdco III at that time. ... In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX a number of common shares equal to the number of XXXXXXXXXX common shares held by Holdco IV at that time. ... Paragraph 85(1)(h) will apply to deem that the cost to XXXXXXXXXX of the XXXXXXXXXX common shares received as consideration for the transfers described in paragraphs 27 and 30 above will be the agreed amount in respect of the Holdco III common shares and Holdco IV common shares transferred. ...

In consideration for the transfer, Holdco I will issue a demand promissory note, bearing interest at a commercial rate set at the beginning of each quarter reflecting XXXXXXXXXX weighted average cost of short-term borrowings, with a principal amount of $XXXXXXXXXX (the "Holdco I Note") and XXXXXXXXXX common shares. ... In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX common shares. ... Paragraph 85(1)(h) will apply to deem that the cost to XXXXXXXXXX of the XXXXXXXXXX common shares received as consideration for the transfers described in paragraphs 27 and 30 above will be the agreed amount in respect of the Holdco I common shares and Holdco II common shares transferred. ...

In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX a number of common shares equal to the number of XXXXXXXXXX common shares held by Holdco I at that time. ... In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX a number of common shares equal to the number of XXXXXXXXXX common shares held by Holdco II at that time. ... Paragraph 85(1)(h) will apply to deem that the cost to XXXXXXXXXX of the XXXXXXXXXX common shares received as consideration for the transfers described in paragraphs 27 and 30 above will be the agreed amount in respect of the Holdco I common shares and Holdco II common shares transferred. ...

As consideration, Newco will issue XXXXXXXXXX Class XXXXXXXXXX shares to Holdco 2. ... The amount to be specified will be equal to the fair market value of the consideration for which the share is issued. ... As consideration, Company will receive as absolute payment, a demand non-interest-bearing promissory note from Newco (the "Newco Note"). ...

XXXXXXXXXX will transfer to XXXXXXXXXX, at fair market value, all of the Class XXXXXXXXXX Shares it holds in XXXXXXXXXX in consideration of the issuance by XXXXXXXXXX. ... No portion of the XXXXXXXXXX liabilities of XXXXXXXXXX will be treated as being assumed in consideration for the transfer of a particular asset by XXXXXXXXXX to the extent that the principal amount of the liabilities exceeds the agreed amount in respect of the transfer of that asset by XXXXXXXXXX. 36. ... No portion of the XXXXXXXXXX will be treated as being assumed in consideration for the transfer of a particular asset by XXXXXXXXXX to the extent that the principal amount of the liabilities exceeds the agreed amount in respect of the transfer of that asset by XXXXXXXXXX. 42. ...

In addressing the issues, you request that we take into consideration the representations made by a taxpayer's representative in a particular factual situation. ... The fact that no revenue was generated during this period was held not to be a significant consideration in determining whether the business had commenced and was being carried on. ... Whether or not a taxpayer is carrying on business inside or outside Canada is determined under Canadian jurisprudence with no consideration given to the extended meaning under section 253 of carrying on business in Canada. ...

The trust will transfer certain of its property (XXXXXXXXXX Class "C" Common Shares of Opco and its XXXXXXXXXX shares of Publico) to Opco in exchange for consideration consisting of preference shares and common shares of Opco. ... G's income interest and any discretionary capital interest in the Class "B" Non-Voting Common Shares and the Class "C" Preference Shares held by the Trust for no consideration. ... The Contingent Income Beneficiaries will also release or surrender their interests in the Trust by executing a Deed of Disclaimer for no consideration and they will not direct in any manner who is to receive the benefits under the Trust. 21. ...

The authorized share capital of Newco Canada will consist of an unlimited number of voting common shares and XXXXXXXXXX non-voting preferred shares which will be redeemable and retractable for an amount equal to the consideration for which they are issued. ... These accounts receivable will be disposed of for consideration that consists only of money. ... In consideration for the transfer, Newsub will issue common shares to XXXXXXXXXX and assume the current liabilities relating to the XXXXXXXXXX and will assume a certain amount of XXXXXXXXXX long-term debt. ...