Search - consideration
Results 3651 - 3660 of 13709 for consideration
Ruling
2015 Ruling 2015-0579791R3 - Split-Up Butterfly
Class A Special Share is redeemable and retractable for a redemption amount equal to the FMV of the property transferred to V Inc. in consideration for the first issuance of the V Inc. ... Class C Special Shares held by DC for aggregate consideration of $XXXXXXXXXX which will be paid by cash or cheque to DC. 53. ... The property transferred by DC to TC will include XXXXXXXXXX% of the Subco Class A Common Shares acquired by DC in consideration for the transfers of Property 1 and Property 2 by DC to Subco. ...
Ruling
2011 Ruling 2010-0380621R3 - Public company spin-off butterfly
As sole consideration for the DC Common Shares transferred to it, DC will issue to each Participant only one DC New Common Share and one DC Butterfly Share for each DC Common Share transferred by the particular Participant. ... As sole consideration for each Butterfly Share transferred to it, Spinco will issue to each Participant one Spinco Common Share. ... The issuance by Spinco of the Spinco Stock Options will be in anticipation of the transfer of the Spin-off Property as described in Paragraph 29 and will form part of the non-share consideration relating to such transfer. ...
Ruling
2008 Ruling 2007-0221361R3 - Alter Ego Trust Planning
Individual A will contribute the Distributed Property to the capital of the New AE Trust for no consideration. ... The rights and restrictions attached to the New Aco Shares will provide that: (a) the New Aco Shares will be redeemable and retractable preferred shares without par value; (b) the aggregate redemption price of the New Aco Shares shall be equal to the fair market value of any consideration received by Aco in consideration for the issuance of such shares; and (c) upon the issuance of the New Aco Shares, the directors of Aco shall add such amount as they shall determine to the stated capital account, provided that such amount shall not exceed the value of the consideration received for the issuance of such shares. 21. ... Cash consideration will be allocated to each Subject Aco Share, Subject Bco Share and Subject Cco Share exchanged under the Share Exchange Agreements. 38. ...
Ruling
2004 Ruling 2004-0080301R3 - sequential spin-off butterflies (no-types-property
BCo Subco will add to the stated capital account of the BCo Subco Common Shares issued as consideration for the transfer of the CCo Reorganization Shares an amount not to exceed the paid-up capital of the CCo Reorganization Shares that BCo transferred to BCo Subco at that time. 47. ... As consideration for the transfer, BCo Subco will issue BCo Subco Preferred Shares to CCo having an aggregate redemption amount (the "BCo Subco Redemption Amount") equal to the aggregate fair market value at that time of the XXXXXXXXXX/DCo Shares that CCo transferred to BCo Subco. ... ACo Subco will add to the stated capital account of the ACo Subco Common Shares issued as consideration for the transfer of the BCo Reorganization Shares an amount not to exceed the paid-up capital of the BCo Reorganization Shares that ACo transferred to ACo Subco at that time. 53. ...
Ruling
2022 Ruling 2022-0941371R3 - Post-mortem tax planning
As consideration for the Holdco Common Shares, Holdco will issue the following shares in its capital stock to the Estate: a. ... As sole consideration for the redemption, Opco will issue the Opco Note to Holdco having a principal amount and FMV equal to the Opco X Redemption Value. ... As sole consideration for the redemption, Holdco will endorse the Opco Note in favour of the Estate. ...
Ruling
2009 Ruling 2009-0330881R3 - Foreign Mergers
New Finco will issue a note payable to Newco 4 as consideration for the interest in Opco 10. ... In accordance with the Foreign Legislation, each agreement of merger will provide, inter alia, that, upon the effective time of the merger: Opco 3 will be the surviving entity of the merger; the sole consideration that New Finco will receive upon the surrender of its shares of Opco Group 5 Parent 3 and Opco Group 5 Parent 4 will be shares of Opco 3; the sole consideration that Opco Group 5 Parent 1, Opco Group 5 Parent 3 and Opco Group 5 Parent 4 will receive upon the surrender of the shares of its subsidiary will be shares of Opco 3; the sole consideration that Opco Group 5 Parent 2 and Opco Group 5 Parent 3 will receive upon the surrender of the shares of Opco Group 5 Parent 1 will be shares of Opco 3; the shares of Opco 3 held by Opco Group 5 Parent 1, Opco Group 5 Parent 2, Opco Group 5 Parent 3 and Opco Group 5 Parent 4 will be cancelled; all rights and property of whatever nature vested in Opco Group 5 Parent 1, Opco Group 5 Parent 2, Opco Group 5 Parent 3 and Opco Group 5 Parent 4 before its merger into Opco 3 will be vested in Opco 3 immediately after the merger without any further act or deed by Opco 3; any intercompany debt that is outstanding between Opco 3 and the corporation being merged into Opco 3 immediately before the merger will be settled on the merger; and Opco 3 will assume all of the remaining liabilities and other debt obligations of each corporation in Opco Group 5. 44. ... Paragraph 69(1)(b) of the Act will apply to any of the share dispositions referred to in Ruling M above if Opco Group 1 Parent, each of the corporations in Opco Group 1 Parents, Subco, Opco Group 3 Parent, each of the corporations in Opco Group 3 Parents, Opco 4, Opco Group 5 Parent 1, Opco Group 5 Parent 2, Opco Group 5 Parent 3, Opco Group 5 Parent 4, Opco 2, Newco 1, New Finco or Opco 6, as the case may be, receives no consideration for such shares or receives consideration that is less than the fair market value of such shares at the time of the disposition. ...
Ruling
2016 Ruling 2015-0616291R3 - Cross-Border Butterfly
The consideration for the transfers described in (c)(i) will be for either cash or a note payable, and any note payable will immediately be capitalized for share consideration as part of the Proposed Transactions. ... Forco 2 will subscribe for units of Foreign DC upon its formation for nominal cash consideration. ... These purchases and sales are generally made for cash or other non-share consideration. ...
Ruling
2010 Ruling 2009-0350711R3 - Debt restructuring and forgiveness
Upon incorporation, Opco will subscribe for common shares of Newco for a nominal consideration. 27. ... In consideration of the issuance of shares of New Forco to the Second Lien Lender, Opco will issue non-interest bearing debt to New Forco for the value of the New Forco shares issued to the Second Lien Lender. ... At the Effective Time, New Forco will acquire XXXXXXXXXX % of the existing common shares of Forco for a nominal consideration (i.e. total purchase price of XXXXXXXXXX $XXXXXXXXXX), being their estimated FMV, pursuant to a share purchase agreement with the existing shareholders of Forco, thereby triggering an acquisition of control of Forco and its direct and indirect subsidiaries. ...
Ruling
2016 Ruling 2015-0623731R3 - Subsections 55(2) and (2.1)
Each of Corp4 and Sub2 transferred substantial assets relating to the XXXXXXXXXX and the Sub2 XXXXXXXXXX to Partnership in consideration for partnership units of Partnership. 16. ... The consideration for the shares of Corp2 was paid by delivery of cash to the shareholder of Corp2. ... Sub1 will issue common shares (the “New Sub1 Shares”) to Parent in consideration for the transfer of the Transferred Sub2 Shares. ...
Ruling
2006 Ruling 2006-0173211R3 - Income Trust Reorganization
Upon incorporation, the Fund will subscribe for one common share of GPco for nominal consideration. ... Upon formation, GPco will subscribe with nominal consideration for a general partner interest in the Partnership and Holdco will subscribe with nominal consideration for one Partnership Unit. ... For the purposes of each election, the agreed amount will not exceed the fair market value of the transferred property, nor will it be less than the fair market value, at the time of disposition, of any consideration other than an interest in the partnership. 22. ...