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However, subsections 15(1), 56(2), 245(2) and 214(3) could be considered if the consideration paid by Canco for the non-voting preferred shares exceeds the fair market value thereof. ...

Acquisition of Property in Contemplation of the Transfer If a particular corporation transfers property to a wholly owned subsidiary in consideration for shares and then transfers such shares to a shareholder corporation as part of a butterfly, Revenue Canada Taxation considers that the transfer to the subsidiary is part of an indirect transfer of the property of the particular corporation to a transferee and that paragraph 55(3)(b) would not apply unless the subsidiary is wound up following the transfer of its shares to the shareholder corporation. ...

Concurrently with the issue of the new preference shares, Famco also issues additional common shares to the Son in consideration for a subscription price equal to their fair market value (based on the fair market value of an existing common share of Famco held by the Son). ...

We would further suggest that any exceptions to this position be referred to this Directorate for consideration on a case by case basis. ...

Ainsi des considérations judiciaires ont été faites par les cours anglaises sur la portée d'application des mots garde et surveillance. ...

Jack mentionnent: "The calculation of a gross premium, i.e. that actually charged by the life insurance company involves consideration of the actual mortality, interest, and expenses being experienced or expected to be experienced during the life of the policy... ...

Although a memorandum in our research files (working papers I and J) supports the interpretation given in paragraph 3, it is not apparent that subsections 11(1) and (2) and paragraph 20(1)(t) were given adequate consideration at the time the interpretation was given. ...

The issue under consideration is whether the assistance is in the nature of a debt settlement for the purposes of section 80 or whether it is an inducement or assistance pursuant to paragraph 12(1)(x). ...

We understand the term "premium" to denote the total amount paid to an insurer in consideration for insurance coverage. ...

(c) New Xco will then redeem its preferred shares held by Brother Xco, the consideration being a demand promissory note having a value equal to the redemption amount. ...