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Parent assumption of SERP Obligations Pursuant to the terms of a Consent, Assignment and Release Agreement that will be entered into with each Pensioner, each Pensioner will permit Opco to assign to Parent, and Parent to assume from Opco, the SERP Obligations, and Opco will assign to Parent, and Parent will assume, all of the SERP Obligations for no consideration. ... Wind-ups Opco will transfer certain of its assets, if any, that have accrued gains to Holdco for cash consideration equal to the FMV of such assets so transferred. ...

Proposed transactions Bco will incorporate a new wholly-owned subsidiary (“Lossco”) and subscribe for Lossco common shares for nominal consideration. Cco will incorporate a new wholly-owned subsidiary (“Newco 1”) and subscribe for Newco 1 common shares for nominal consideration. ...

Preliminary transactions After redeeming the Class B and C preferred shares through the issuance of demand promissory notes (with no resulting deemed dividend or capital gain to the estate), ACo will purchase for cancellation (in consideration for issuing a demand promissory note) a sufficient such number of its Class A shares to result in a refund of its eligible refundable dividend tax on hand, or its non-eligible refundable dividend tax on hand, balances. ... Proposed transactions The Estate will transfer its remaining Class A shares (electing under s. 85(1)) to a newly-incorporated corporation formed by it (“Newco”) in consideration mostly for a note (the “Note 6”) with a principal amount and FMV equal to the lesser of such shares’ current FMV and their (stepped-up) ACB, and for a Class A (common) share of Newco. ...

Preliminary transactions Opco redeemed Class E shares in consideration for Note 1 and designated the resulting deemed dividend as an eligible dividend, with the estate carrying back the resulting capital loss to it under s. 164(6). ... Proposed transactions The estate will transfer its Class A shares of Opco 2 to a corporation newly incorporated by it (“Newco”) in consideration for a note (“Note 5”) and for Class B non-voting redeemable retractable shares, electing under s. 85(1) and with a price adjustment clause. ...

Proposed transactions The estate will transfer its Class A and Class E shares of the Corporation to a newly-incorporated corporation (“Newco” – whose voting common shares are held by it) in consideration for Class A common shares and a Newco and two non-interest-bearing notes (“Note 1” and “Note 2”), electing under s. 85(1). ... Trusts 1, 2 and 3 will transfer their Class J shares of the Corporation to Newco in consideration for Class F shares of Newco, electing under s. 85(1). ...

The Corporation will redeem the Class A Preferred Shares in consideration for a demand noninterest bearing promissory note, designate a portion (not exceeding its GRIP account) as an eligible dividend pursuant to s. 89(14) and report a resulting capital loss, which will be carried back under s. 164(6). ... The Estate will transfer the Class A Common Shares to a “Newco” formed by it in consideration for Newco common shares, electing under s. 85(1). ...

Fund LP will transfer the Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new LP (New LP – formed by General Partner LP as general partner and Fund LP as limited partner, and) in consideration for units of New LP, with similar terms to Fund LP, except that distributions are solely in proportion to the number of units held. ... The other former partners will sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...

Fund LP transfers its Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new subsidiary LP (New LP) in consideration for the plain-vanilla units. ... The other former partners sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...

12 July 1995 Ruling File No. 11755-20-- summary under Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Service "A Tenant inducement is interpreted as being consideration for the supply of a service which occurs at the time the lease is signed. ...

2000 Ruling 1999-001074-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) S.85(1)(b) would not apply where the portion of liabilities assumed by the transferee that were in excess of the cost amount of the transferred property were so assumed in consideration for a cash payment. ...