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Results 3591 - 3600 of 13709 for consideration
Miscellaneous severed letter

2004 Income Tax Severed Letter 2004-0056501 - Transfer of Business

"On XXXXXXXXXX XCO subscribed for one common share of Subco for nominal consideration which was satisfied by the transfer of the goodwill associated with the employees of BusinessA which were transferred to Subco as described in paragraph 28. ... A new paragraph 27.2 is added as follows: "XCO will grant a license to PartnershipA to use the XCO name and trademarks for fair market value consideration." ... In consideration for the assumption of the obligation to issue warrants and options, and in satisfaction of the redemption price for the Class C Preferred Shares, Aco will transfer the approximate XXXXXXXXXX% general partnership interest and cash to Newco. ...
Ruling

2004 Ruling 2004-0069751R3 - Buy, Bump and Sell Transactions

("Transferee1"), which is wholly-owned by Sibling1, in exchange for fair market value consideration being newly issued shares of Transferee1. ... ("Transferee2"), which is wholly-owned by Sibling2, in exchange for fair market value consideration being newly issued shares of Transferee2. 18. ... As consideration for such redemption, Farmco1 will transfer its surplus assets to Transferee1 and Farmco2 will transfer its surplus assets to Transferee2. ...
Ruling

2004 Ruling 2004-0065611R3 - Single-wing Butterfly

Each preferred share will be redeemable and retractable for an amount equal to the FMV of the consideration received by Newco for the issuance of the share. ... As consideration for the transfers of property described above in paragraph 11, Subco will issue to DC XXXXXXXXXX common shares of Subco. 13. ... As consideration for the transferred shares, Newco will issue XXXXXXXXXX common shares to Y. ...
Ruling

2000 Ruling 2000-0055693 - reorganization

Notwithstanding that the preferred shares will be subject to a price adjustment clause, for the purposes of subsection 191(4), the directors will specify an amount per share not to exceed the fair market value of consideration for which the share was issued. ... There will not be any liabilities assumed by any of the shareholders as consideration for the transferred properties. ... In consideration, Aco will issue to each of its shareholders a non-interest-bearing demand promissory note having a principal amount and fair market value equal to the fair market value of the Aco shares so purchased from that shareholder (the "Aco Notes"). ...
Ruling

2000 Ruling 2000-0045853 - Substituted Property

XCO will subscribe for common shares of BCO at $XXXXXXXXXX per share for consideration consisting of approximately $XXXXXXXXXX in cash. ... XCO will transfer to Parentco all of its shares of ACO and the Second Note in consideration for common shares of Parentco. ... YCO1 will contribute cash of approximately $XXXXXXXXXX to Parentco in consideration for common shares of Parentco. ...
Ruling

2002 Ruling 2002-0132913 - SAME BUSINESS

Company A3 will sell its undivided interest in each of the assets received on the dissolution of Partnership C to Company B at fair market value for cash or other consideration. 29. ... Company B will sell its undivided interest in each of the assets received on the dissolution of Partnership A to Company C at fair market value for cash or other consideration. 31. Company A1 will sell its undivided interest in each of the assets received on the dissolution of Partnership A to Company C at fair market value for cash or other consideration. ...
Ruling

2003 Ruling 2002-0175753 - Butterfly

SIB2 will sell to Opco his XXXXXXXXXX DC Class C Shares, which represent all of his shareholdings in DC, for consideration consisting solely of XXXXXXXXXX Opco Common Shares, such that the aggregate FMV of the XXXXXXXXXX Opco Common Shares so issued is equal to the aggregate FMV of the XXXXXXXXXX DC Class C Shares. ... For greater certainty, the agreed amount for any eligible property included in the subsection 85(1) election referred to herein will not exceed the FMV of such property and will not be less than the amount of any liabilities assumed by Opco as consideration of such property. ... Consideration to avoid land transfer tax XXXXXXXXXX if it occurs as part of a reorganization that qualifies under paragraph 55(3)(b) of the Act, such that the transfer of the real estate to Opco may be exempt from XXXXXXXXXX land transfer tax. ...
Ruling

2000 Ruling 2000-0031583 - Reduction in PUC of Public Corp.

The details of the share, debenture and option consideration to be issued is described below. ... XXXXXXXXXX may issue shares for cash consideration of less than XXXXXXXXXX per share (the "Financing Shares") to raise additional cash. ... In consideration for he transfer of the XXXXXXXXXX Business, Newco will issue to Holdco Newco Shares with a fair market value equal to the fair market value of the XXXXXXXXXX Business at the time of the disposition. ...
Ruling

2000 Ruling 2000-0041953 - Reorganization

XXXXXXXXXX preferred shares are voting; non-participating; entitled to a discretionary, fixed, non-cumulative dividend in the amount of XXXXXXXXXX% per quarter of the fair market value of the consideration for which such shares were issued; and redeemable at the option of the corporation and retractable at the option of the holder thereof for the fair market value of the consideration for which such shares were issued. ... As consideration therefor, each of Newco B and Newco C will assume liabilities of Aco and, as additional consideration, Newco B and Newco C will issue XXXXXXXXXX shares of Newco B and Newco C having a fair market value and redemption amount equal to the amount by which the aggregate fair market value of the properties received by the respective transferee exceeds the fair market value of the liabilities assumed by that transferee. 27. ... In each case, the agreed amount will neither exceed the fair market value of the particular property transferred nor be less than the amount of any liabilities assumed by the transferee as consideration for the transfer of such property. ...
Ruling

1998 Ruling 9807993 - SPLIT-UP BUTTERFLY

On incorporation Opco will subscribe for XXXXXXXXXX common shares of Subco for nominal consideration. 8. ... In each case, the agreed amount will not exceed the fair market value of the respective property, nor will it be less than the amount of any liabilities assumed by Newco as consideration for the transfer of such property. 15. ... On the next day, Newco will sell for cash consideration its Subco shares and Subco promissory note to Opco at their fair market value. ...

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