Search - consideration

The consideration for the granting of the Canadian Licence will be equal to the value of the rights granted to the UK Co-Producer, which shall be payable at the end of XXXXXXXXXX years. 13. ... The date of payment and the consideration payable to the UK Co-Producer under the Canadian Sublicence will be the same as provided for in the Canadian Licence and these monetary obligations will be extinguished by way of set-off at the end of XXXXXXXXXX years. ...

We have indicated that, based on the representative's representations and our prior consideration of the use of surplus by employers and employees, it appears to us that the right to the surplus may only be established when approval to withdraw the amount has been obtained from the appropriate authorities. ... This approach, however, ignores the fundamental nature of dividends, i.e., a payment which is related by way of entitlement to one's capital or share interest in the corporation, and not to any other consideration, such as the shareholder's level of contribution to the corporation, or the existence of a non-arm's length transaction. ...

The additional amount of dividends will reflect the estimated time utilization of the non-capital losses of Topco and other consideration and is estimated for the purposes of this ruling to be no more than XXXXXXXXXX% of the amount of the non-capital losses utilized in the year. 9. ... None of the issued shares referred to herein (including the shares to be issued as described in the Proposed Transactions) are or will be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) 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). 22. ...

Another consideration is whether the issuance of promissory notes will constitute payment of income. ... Thus, the promissory notes will be truly payable on demand. 6 The trust will qualify as a personal trust since the First Nation will be the settlor of the trust and the interest will not be acquired for consideration. ...

H) Provided that XXXXXXXXXX has included or will have included an amount in respect of the undertakings related to the XXXXXXXXXX as described in paragraph 21 above, in computing its income from its business pursuant to 12(1)(a) of the Act which includes the time of the transfer of the assets described in paragraph 37 above or any preceding taxation year, the payment made by XXXXXXXXXX to XXXXXXXXXX in consideration for the assumption by XXXXXXXXXX of those undertakings, to the extent that the payment is reasonable: (i) may, pursuant to paragraph 20(24)(a) of the Act, be deducted in computing the income of XXXXXXXXXX for its fiscal period in which the payment takes place; and (ii) will, pursuant to paragraph 20(24)(b) of the Act, be deemed to be an amount described in paragraph 12(1)(a) thereof in respect of XXXXXXXXXX. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

The aggregate consideration payable by Acq. Co. for the Holdco shares under the Purchase Agreements will be identical to the consideration that the Holdcos would have been entitled to receive had they tendered the XXXXXXXXXX shares held by them directly under the Offer. 35. ...

Newco will be incorporated under the laws of the Province, being authorized to issue XXXXXXXXXX common or ordinary shares without nominal or par value, of which one (1) common share will be issued for the benefit of a Principal for which Newco will receive future consideration from the Partnership. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

In consideration for arranging the Primary Loans and the Secondary Loans, the Agent will be entitled to receive a fee (the "Loan Arrangement Fee") from each Limited Partner, the amount of which will be equal to the fair market value of such services estimated to be approximately $XXXXXXXXXX per Unit purchased by such Limited Partner. ... In consideration for its services, XXXXXXXXXX will agree to pay the XXXXXXXXXX Facilitator a fee (the "XXXXXXXXXX Arrangement Fee"). ...

Le transfert du savoir de l'OSBL à une autre OSBL sous forme de licence ainsi que la considération reçue à cet égard lui fera-t-elle perdre son statut en vertu de 149(1)l)? ... Toutefois, le commandité devra prendre en considération les aspects suivants dans sa gestion courante: a) XXXXXXXXXX b) XXXXXXXXXX c) XXXXXXXXXX d) XXXXXXXXXX 33. ...

In consideration for the redeemed shares, Newco will issue a demand promissory note to Holdco (the "Newco Note") having a principal amount and a fair market value equal to the total of the redemption prices of its Class C and D special shares so redeemed. ... In consideration for the purchased/redeemed shares, Holdco will issue a demand promissory note to Newco (the "Holdco Note") having a principal amount and a fair market value equal to the total of the fair market value of the common shares so purchased and the redemption amounts of the Class A and Class B special shares. ...