Search - consideration

In Black's Law Dictionary (6th Edition), they are defined as follows: "rent": consideration paid for use or occupation of property; (in a broader sense) compensation or fee paid, usually periodically, for the use of any rental property, land, buildings, equipment, etc. ...

All of the then issued and outstanding common shares of Old Canco were acquired by Subco on XXXXXXXXXX in consideration for exchangeable preference shares of Subco, exchangeable at the option of the holder for special voting shares of Parentco. ...

Indeed the CRA could consider the disposition of the “new” common shares of the capital stock of OPCO held by the Related Person as being part of a series of transactions or events in which the Old Common Shares were acquired by OPCO for consideration that was significantly less than their FMV at the time of acquisition. ...

The Taxpayer will receive no consideration for providing Guarantees in respect of the XXXXXXXXXX-insured Sub-Partnership Borrowings nor will any benefit be received by, or any form of compensation (including reciprocal guarantees) be paid or payable to, the Taxpayer or its unit holders in respect of the Guarantees. 20. ...

In substance, the Arrangement provided that each shareholder of Pubco would receive either: (i) XXXXXXXXXX Fund Units XXXXXXXXXX as consideration for the disposition of each common share of Pubco on a fully taxable basis; or (ii) XXXXXXXXXX Class B LP Units XXXXXXXXXX for each common share of Pubco in which case the shareholder was eligible, in certain circumstances, to make an election under subsection 97(2) in respect of such exchange. 3. ...

E-13 was mandatory, this finding was based on the wording of the particular legislation under consideration. ...

Pour répondre de façon succincte à la question d'interprétation que vous nous soumettez, nous sommes d'avis qu'on ne peut pas prendre en considération seulement le solde du compte d'IMRTD d'une sociétés donnée immédiatement avant la réception d'un dividende par celle-ci aux fins du calcul du RTD ou de l'impôt de la partie IV de cette société ou d'une autre société pour une année d'imposition donnée. ...

Bidco will acquire all the issued and outstanding common shares of the capital stock of Pubco for consideration of $XXXXXXXXXX per share, such that Pubco will become a wholly-owned subsidiary of Bidco. ...

An employer's arrangement will be considered an IP if: the employer makes contributions; the arrangement covers two or more employees; and the arrangement contains an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

In the context of a wind-up, the transfer may be treated as consideration for the disposition by the member of his membership rights, generally viewed by CRA as capital property. ...