Search - consideration

Paragraph (b) of the definition of CCPC provides notably for the situation where a corporation would be controlled by a particular person, if each share of the capital stock of the corporation that is owned by a non-resident person were owned by the particular person. a) De Jure Control and Option Holding For the purposes of this definition, we must also take into consideration the options held by a person because of paragraph 251(5)(b) I.T.A. ...

To the best of your knowledge and that of the Partnership, Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico, none of the issues involved in this ruling is: (a) relevant to a tax return previously filed by Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (b) under consideration by a tax services office or taxation centre in connection with a previously filed tax return of Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (c) under objection by Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (d) the subject of a ruling previously issued by this Directorate to the Partnership, Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; or (e) before the courts or if a judgment has been issued, the time for an appeal to a higher court has not expired. ...

In consideration of granting the Canadian License, Can Production Co will receive from UK Co. #1 a lump sum amount of approximately $XXXXXXXXXX, which is approximately XXXXXXXXXX% of Can Production Co's costs of production (the "Initial Amount") and a lump sum payment of $XXXXXXXXXX (the "Additional Payment") to be made on the fifteenth anniversary of the completion date (the "Completion Date") of the sale/leaseback transaction in paragraph 12 below, provided that the Series has generated gross receipts (excluding VAT and any equivalent taxes) of $XXXXXXXXXX (excluding presales) and net of any commissions and other costs of distribution (the "Gross Receipts"). ...

The Situation In summary, the situation under consideration, as we understand it, is as follows: XXXXXXXXXX (OPCO I) and XXXXXXXXXX (OPCO II) are private corporations and Canadian-controlled private corporations, as defined under subsections 89(1) and 125(7) of the Act, respectively. ...

The New Preferred Shares will not be, at any time during the implementation of the proposed transaction:- the subject of any undertaking that is referred to in subsection 212(2.2) as a guarantee agreement,- the subject of a dividend rental arrangement as the term is defined in subsection 248(1),- issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)) or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 26. ...

A Special Corporate resolution provides for the issuance of shares and immediate conversion into shares of the merged corporation at the merger exchange rate. 2) Since the bonus plan is a separate and distinct plan, we can accept that the bonus is not consideration for the exchange of the options. ...

In our opinion, the position in the original interpretation is supported in law when due consideration is given to the nature of a co-owner's rights in a particular piece of land. ...

Nous vous fournissons des éléments de droit qui peuvent être pris en considération dans l'analyse de votre dossier. ...

The licensor can "pull-back" shows from the taxpayer after one or two showings without paying much or any consideration. 9. ...

With respect to the cost to Parentco of Canco XXXXXXXXXX Shares as a result of the exercise of the right of first refusal by Parentco, we are of the opinion that such cost would be equal to the stated capital or paid-up capital of the common shares of Parentco issued to XXXXXXXXXX in consideration for the transferring of the Canco XXXXXXXXXX Shares to Parentco by XXXXXXXXXX. ...