Search - consideration

(a company organized under the laws of the State of XXXXXXXXXX that dealt at arm's length with the Principal's group of companies) for total consideration of US $XXXXXXXXXX in cash plus various adjustments and the assumption of various liabilities on closing. 9. ... ForeignCo will incorporate a new Canadian company ("Newco 1") under the laws of the Province for nominal cash consideration. 19. ... No non-share consideration will be issued by Newco 1 as part of the exchange. ...

Les gains et pertes en capital sont pris en considération à l'alinéa a) de la définition de CDC. ... Les ajustements prévus au paragraphe 111(1.1) pour les fins de l'alinéa 111(1)b), ne sont pas pris en considération pour les fins du calcul du CDC. ... Par conséquent, pour les fins du calcul du CDC de AMALCO dans la situation décrite ci-dessus, il faudrait prendre en considération la perte en capital (1 690 000 $) et la perte en capital déductible (1 267 500 $) de PARENTCO. ...

On XXXXXXXXXX, Parent and XXXXXXXXXX, announced the agreement for the acquisition of Parent by XXXXXXXXXX for total consideration of $XXXXXXXXXX U.S. including assumed net debt of $XXXXXXXXXX U.S., at an agreed price of $XXXXXXXXXX U.S. per share in cash (the "Merger Agreement"). ... In respect of employees of the Corporation that hold Parent Options (the "Employees"), the Merger Agreement generally provides for the following: (a) subject to (c) below, each vested Parent Option held by an Employee will be cancelled by Parent and each holder of such cancelled and vested Parent Option will be entitled to receive from Parent or, at Parent's option, from any related corporation in consideration for such cancellation an amount in cash equal to the product of the number of Parent Shares subject to the vested Parent Option multiplied by the excess, if any, of the price per Parent Share paid by XXXXXXXXXX under the Merger Agreement (the "Per Share Merger Consideration") when the merger is completed (the "Merger Date") over the exercise price per Parent Share under the Parent Option. ... As a result of the Binding Agreement and the Demerger, each Employee will dispose of his or her rights to acquire shares under the Parent Options for consideration consisting solely of rights under the Binding Agreement and the amount by which the total value of the XXXXXXXXXX Shares, on the date of the Merger, that the Employee may purchase under the XXXXXXXXXX Option to be issued under the Binding Agreement exceeds the total amount payable by the Employee to acquire such XXXXXXXXXX Shares under the Binding Agreement does not exceed the amount by which the total value of the Parent Shares that the Employee may have purchased under the Parent Options immediately before their disposition (as of the date of the Merger) would have been payable by the Employee to acquire the Parent Shares under such Parent Options. 12. ...

Subco 1 will issue one common share to Sco as the sole consideration for the Existing Xco Shares. ... Subco 2 will issue one common share to Subco 1 as the sole consideration for the Existing Xco Shares. ... In consideration, Xco will issue XXXXXXXXXX common shares (the “New Xco Shares”) to Subco 1 as the sole consideration for the Subco 2 common shares. ...

Aco will immediately use the borrowed funds to acquire from Bco and from Cco additional Class A common shares of each of Bco and Cco for cash consideration of $XXXXXXXXXX per share. 1O. Each of Bco and Cco will add to the stated capital account maintained by it in respect of its Class A common shares the full amount of the cash consideration received by it from Aco as consideration for the issuance of the shares. ... Subsequently, Bco transferred XXXXXXXXXX% of the beneficial interest in the XXXXXXXXXX property to Dco in consideration of an interest-free note payable on demand. ...

With respect to all of the payments referred to above that are made pursuant to an insurance policy, one consideration is whether an "employee benefit plan" or an "employee trust" exists pursuant to the definitions of these terms in subsection 248(1) of the Income Tax Act (the Act). ... A second consideration is whether deductions in respect any of the payments can be claimed under subparagraph 110(1)(f)(ii) of the Act. ... In view of the foregoing, it would appear that a consideration would be whether it is possible to establish a private health services plan that can be regarded as a separate plan within an insurance policy. ...

As consideration for the transfer of the property and the promissory note, Subco assumes the mortgage and giyes Holdco common shares and redeemable preference shares with a redemption price equal to the amount of the promissory note. ... The word implies the existence of a debtor, legality of the obligation, the existence of a consideration, and execution or performance by the creditor. ... Conclusion A copy of this decision summary will be forwarded to Finance for consideration in their ongoing interest study. ...

A flow-through share was generally understood to mean a share of the capital stock of a corporation issued by the corporation to a taxpayer in a situation where, pursuant to an agreement in writing entered into before 1987 between the taxpayer and the corporation, the taxpayer agreed to incur CEE described in any of subparagraphs (i) to (iii.1) of paragraph 66.1(6)(a) of the Act solely in consideration for the share or a right thereto or an interest therein.  ... It provides that a taxpayer may include in his CEE, expenses which qualify for treatment as CEE for purposes of the Act which were incurred by him pursuant to an agreement in writing with a corporation, entered into before 1987, under which he incurred the expenses solely as consideration for shares, other than prescribed shares, of the capital stock of the corporation which are issued to him; or any interest in such shares or right thereto. ... The CEE incurred in 1987 and 1988 by the Companies on behalf of the Subscribers of such Rights would thus fall within the ambit of subparagraph 66.1(6)(a)(v) and would be eligible CEE of the Subscribers; provided that the said CEE was incurred pursuant to an agreement in writing entered into before 1987 under which it was incurred solely as consideration for acquiring the Rights; and provided that the Companies have complied with the various conditions set out in the Act concerning the incurrence of CEE. ...

The Court also found that the payment was motivated primarily by considerations extraneous to the employment, namely, public and labour relations considerations. ... The Tax Court found that the amount was not taxable and allowed the appeal on the basis that:-     the payment was not an allowance but partial reimbursement of increased housing costs;-     the payment could not reasonably be regarded as consideration for entering into the contract of employment, notwithstanding that he found that the amount was part of the remuneration package;-     the taxpayer did not receive a benefit, as he was in no better position. ... The judge dismissed the appeal finding that the payment was taxable since it resulted from an obligation under the agreement with the employer, and was received as consideration for accepting the office within the provisions of paragraphs 6(3)(b) and (c) of the Act. ...

In connection with the adverse decision in the Nomad case, Technical Publications Division referred the matter to the Department of Finance ("Finance") on January 7, 1991 for tax policy consideration. ... Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Our Comments Stone Quarry Initially, you mentioned that the quarry under consideration was a "stone quarry". ... Since the limestone deposit under consideration has not been Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information certified as a mineral resource, subsections 1104(5) and (6) of the Regulations do not apply to 24(1) limestone quarry. ...