Search - consideration
Results 3671 - 3680 of 13709 for consideration
Ruling
2020 Ruling 2019-0818261R3 - Split-Up Farm Butterfly
As sole consideration for such transfers, TC1 will issue a number of Class B Special Shares to Mr. ... As consideration therefore, TC1 will issue to DC a non-interest bearing demand promissory note (the “TC1 Redemption Note”) having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class A Special Shares so redeemed by it. ... As consideration therefore, DC will issue to TC1 a non-interest bearing demand promissory note (the “DC Redemption Note”) having a principal amount and FMV equal to the aggregate FMV and/or aggregate redemption amount, as applicable, of such shares so purchased for cancellation or redeemed. ...
Ruling
2009 Ruling 2008-0304371R3 - Single-Wing Butterfly
A Sub Holdco and B Sub Holdco each acquired their Opco Common Shares from its parent company, A Holdco and B Holdco, respectively, on XXXXXXXXXX for share consideration consisting of XXXXXXXXXX common shares issued from their respective treasury stocks. ... On its incorporation, B Sub Holdco subscribed for common shares of B NomineeCo for nominal consideration. 54. ... B Sub Holdco will be authorized to issue an unlimited number of the B Sub Holdco Special Shares each of which will be voting, redeemable and retractable at an amount (the "B Sub Holdco Special Share Redemption Amount") equal to the result obtained when the aggregate fair market value of the property transferred to B Sub Holdco on the date of issuance as consideration for the B Sub Holdco Special Shares less the aggregate amount of the non-share consideration, if any, paid, assumed or delivered by B Sub Holdco for the acquisition of such property is divided by the number of B Sub Holdco Special Shares issued as consideration therefor. 57. ...
Ruling
2012 Ruling 2011-0403291R3 - Treaty exempt sale
Sellco1 transferred all of the issued and outstanding common shares of Canco to Foreignco3 in consideration for $XXXXXXXXXX. 33. ... Sellco2 conveyed ABC Assets to Keepco1 in consideration for XXXXXXXXXX common shares of Keepco1. ... Keepptp1 was dissolved and Sellco1 will assume for nominal consideration all of Keepptp1's rights and obligations. 64. ...
Ruling
2013 Ruling 2012-0443081R3 - Distribution of pre-72 Capital Surplus on Hand
More specifically, XXXXXXXXXX Class B shares of BCo were acquired from Father 1-2 in consideration for XXXXXXXXXX Class E shares of ACo and XXXXXXXXXX Class B shares of BCo were acquired from Father 3-4 in consideration for XXXXXXXXXX Class E shares of ACo. ... The Class Z.2 preferred shares will be redeemable and retractable for the fair market value of the consideration for which they were issued. ... ACo will transfer its BCo Shares to Newco and will receive as consideration Class 4 preferred shares of Newco having an aggregate redemption value equal to the fair market value of the transferred BCo Shares. ...
Ruling
2009 Ruling 2007-0256411R3 - Public butterfly
Each non-voting second preference share was issued for consideration, the FMV of which was equal to the cost of the share to the original owner at the time of its issuance. The PUC of the class of non-voting second preference shares is equal to the FMV of the consideration for which the outstanding shares were issued. ... The amount to be specified will not exceed the FMV of the consideration for which the share is issued. ...
Ruling
2007 Ruling 2007-0223921R3 - XXXXXXXXXX - Sequential S-Off Butterfly
On the incorporation of Bare Trusteeco each of Sibling1 and Sibling2 will subscribe for XXXXXXXXXX common shares in Bare Trusteeco for nominal consideration. ... For the purposes of the BCA, the addition to the stated capital of the New Subco Common Shares issued by New Subco to DC as consideration for the DC Sub Class C Shares transferred to New Subco, as described in Paragraph 21, will be equal to the paid-up capital of the DC Sub Class C Shares, being $XXXXXXXXXX. 23. ... For the purposes of the BCA, the addition to the stated capital of the New Holdco Common Shares issued by New Holdco as consideration for the DC Class C Shares transferred to it, as described in Paragraph 36, will equal the paid-up capital of the DC Class C Shares, being $XXXXXXXXXX. ...
Ruling
2005 Ruling 2005-0126111R3 - Spin-off butterfly
Aco's acquisition of its XXXXXXXXXX% interest in the XXXXXXXXXX from DC and DC's acquisition of the XXXXXXXXXX common shares of Aco as partial consideration therefore, did not take place in contemplation of the Proposed Transactions. ... Newco has issued one common share for nominal consideration to DC. Newco was originally incorporated by DC to be the transferee corporation in respect of the Proposed Transactions, however, Newco will not be used for this purpose or for any purpose. ... In consideration for the transfer of the Spin-off Assets, Spinco will issue Spinco Special Shares to DC, which will have an aggregate Redemption Amount equal to the net FMV of the Spin-off Assets transferred. ...
Ruling
1999 Ruling 9900133 - BUTTERFLY REORGANIZATION
As sole consideration for the transfer, TC1 will issue common shares to DC2. ... As consideration for the transfer of the TC1 Transferred Assets to TC1, TC1 will assume liabilities of DC1 and issue TC1 Special Shares to DC1. ... In consideration for the transfer of the XXXXXXXXXX Newco Common Shares, TC2 will:. ...
Ruling
1999 Ruling 9902623 - BUTTERFLY REORGANIZATION
In consideration for the transfer, XXXXXXXXXX Subco II will issue to XXXXXXXXXX common shares with a fair market value not exceeding the fair market value of the XXXXXXXXXX Shares at the time of the transfer. ... In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX common shares with a fair market value not exceeding the fair market value of the Transferred Shares at the time of the transfer. ... Newco will add an amount to the stated capital account in respect of its Class XXXXXXXXXX common shares issued as consideration for the transfer of the XXXXXXXXXX New Common Shares not to exceed the excess, if any, of the aggregate paid-up capital of the XXXXXXXXXX New Common Shares over the cash consideration paid by Newco. ...
Technical Interpretation - Internal
28 September 2009 Internal T.I. 2008-0300511I7 - Classification of a foreign entity - Anstalt
For example, an Anstalt may have the following characteristics: Legal personality; Ability to own property; Could sue and be sued; Rights and obligations of its own; May have perpetual existence; Ability to conduct various business pursuits; Limited Liability for the Members; Management centralized in a board of directors elected by the Founder; The Founder's Rights Holder has the right to appoint and remove the Directors; The Founder's rights are assignable and transferable; The Anstalt is incorporated by Articles of Association (like articles of incorporation) and not by a trust deed; A contribution of capital is made to the Anstalt and the minimum amount of capital is fixed by the Anstalt legislation; The beneficiaries did not pay for their interest in the Anstalt and are not entitled to vote; The beneficiaries are named in the Article of Association and are irrevocably entitled to the benefits of the Anstalt; The beneficiaries may derive a present or future advantage from the assets of the Anstalt, be it a share in the revenues or a share in the assets of the Anstalt even if they did not pay any consideration for that right. ...