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Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 26. ...

Based on the context of subparagraph 95(2)(a)(ii) and the implications of the possible interpretations, it is our view that the term "payable" with respect to debt obligations covered by subparagraph 95(2)(a)(ii) means amounts calculated on an accrual basis for the taxation year under consideration. ...

FA2 and New FA3 will enter into a share-for-share transfer agreement pursuant to which all the shares of FA5 owned by FA2 will be transferred to New FA3 in consideration for additional shares of New FA3. ...

In XXXXXXXXXX, ACo granted to XXXXXXXXXX an XXXXXXXXXX in consideration for $XXXXXXXXXX in exploration expenditures and the production of a bankable feasibility study by XXXXXXXXXX. 15. ...

To this end, the following transactions will be carried out: a) Creation of a new corporation ("Newco") and transfer of the third of the shares of Pubco held by the Shareholders in favour of Newco, according to section 85.1 of the ITA and issuance by Newco of shares of its capital stock in consideration. b) Acquisition by Pubco of the shares of its capital stock held by Newco and attribution of the Cash in payment of the acquisition ($10 M). c) Purchase of Opco's shares by Newco in exchange of an issuance of shares of Newco. ...

Après avoir pris en considération tous les faits pertinents, la cour a conclu que l'intention de l'appelant et de sa société mère était de créer une relation prêteur-emprunteur et que la tradition d'argent s'était faite par des entrées comptables appropriées. ...

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 26. ...

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 29. ...

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 22. ...

The Issued Canco Preferred Shares will not be, at any time during the implementation of the proposed transactions described herein: (a) the subject of any undertaking that is referred to in subsection 112(2.2) of the Act as a “guarantee agreement”; (b) the subject of a dividend rental arrangement as that term is defined in subsection 248(1) of the Act; (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). 18. ...