Search - consideration

After 12 months, Newco will reduce the PUC of its common shares by an amount equal to the PUC (apparently, all the PUC) of its common shares in consideration for the issuance of eight non-interest-bearing notes payable over 8 quarters. ...

After having incorporated his or her respective TC (TC1 to 3) and subscribed for Class A voting participating shares, each of Son1, Son2 and Mother transfers his or her DC-Class A and DC Class-D shares to such TC in consideration for non-voting retractable Class C shares of TC, electing under s. 85(1). DC transfers pro rata portions of its three types of property (including the Home Quarter and farm equipment to the TCs as tenants-in-common if not yet sold) to the TCs in consideration for non-voting Class D redeemable retractable shares, electing under s. 85(1). ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts Current structure Forco 1 is held through three stacked Canadian partnerships by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ... Each of Forco 2, 3 and 4 will transfer all of its Forco 5 Shares to DC solely in consideration for a credit to its membership account in DC in the amount of the fair market value of the transferred shares. ...

Holdco 1 under s. 85(1) will transfer XX% and (100-XX)%) of each of its Class A and Class B preferred shares to Newco 1 and 2, respectively, in consideration for non-voting redeemable and retractable Newco 1 or 2 Class A Preferred Shares. ... Canco will transfer Parcel One and Two to Newco 1 and 2, respectively, in consideration for assumption of liabilities (including mortgages) and for Newco 1 or 2 Class B Preferred Shares. ...

2016 Ruling 2015-0623731R3- Subsections 55(2) and (2.1)-- summary under Paragraph 55(3)(a) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) requirement to pro-rate PUC Background As described in 2015-0601441R3, Sub1 and Sub2 (both taxable Canadian corporations and wholly-owned subsidiaries of Parent, a public corporation) accomplished a winding-up of a general partnership (“Partnership”) through a transfer by Sub2 of its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and for a non-interest bearing demand promissory note (the “Sub1 Note”) with a principal amount equal to the non-interest-bearing demand promissory note (the “Sub2-Partnership Note”) owing by Sub2 to the Partnership, jointly electing under s. 85(1). ... " Parent will transfer to Sub1 all of the Sub2 Preferred Shares (the “Transferred Sub2 Shares”) in consideration for the issuance of Sub1 common shares (the “New Sub1 Shares”), electing under s. 85(1) at Parent’s ACB of the Transferred Sub2 Shares. ...

DC1 will transfer under s. 85(1) a pro rata portion of each of its three types of property to SubDC2, SubTC1A and SubTC2 in consideration for the assumption of liabilities and the issuance of special shares, so as to satisfy the percentage test in s. 55(1) – distribution to within 1%. ... DC2 will transfer under s. 85(1) a pro rata portion of each of its three types of property to SubTC1B in consideration for the assumption of liabilities and the issuance of special shares. ...

Transfers by Target shareholders Specified Shareholder transferred Target shares to Parent in consideration for $X and for Class A and Class B common shares. At the Effective Time under the Plan of Arrangement, all the other Target shares were transferred to Parent for cash consideration. ...

After the subscription by Parent for special voting shares and by each Child for common shares of a newly-incorporated TC for each Child (TC1, TC2, TC3 and or TC4), each Child will transfer under s. 85(1) to that Child’s TC a portion of the Child’s DC Common Shares (having an FMV equaling ¼ of the Transaction Assets FMV net of the Parent Note and Parent Note 2 amounts) in each case in consideration for a demand non-interest bearing promissory note of the TC having a principal amount and FMV equal to the PUC and ACB of the transferred shares and for the issuance of additional common shares of the TC. ... DC will transfer 1/4 of the Transaction Assets to each TC in consideration for the assumption of ¼ of the Parent Note and Parent Note 2 and the issuance of non-voting redeemable retractable TC preferred shares, with a joint s. 85(1) election being made. ...

Each child will transfer special C shares of DC (whose number will be affected somewhat by the trading price of certain shares held by DC so as to ensure only a whole number of such shares are transferred in 3 below) pursuant to s. 85(1) to their respective TCs in consideration for common shares of that TC. DC will contemporaneously transfer shares to each of the TCs pursuant to s. 85(1) in consideration for Class A preferred shares of the TC. ...

Each of Holdco1 and Holdco2 will transfer its common shares of DC to a corporation newly-formed by it (TC1 or TC2) on a s. 85(1) rollover basis in consideration for common shares. DC (which will have not investment property) will transfer simultaneously to each of TC1 and TC2 on a s. 85(1)rollover basis 50% of its cash or near-cash and business property, on a gross FMV basis (such that immediately following such transfers the FMV of each type of property so received by TC1 and TC2 will be equal to or will approximate 50% of the FMV of that particular type of property of DC immediately before such transfers) in consideration for the assumption of liabilities and the issuance of redeemable preferred shares. ...