Search - consideration

Pubco will transfer its shares of Canco and Forco1, and a loan owing by Forco1, to Newco mostly in consideration for interest-bearing notes of Newco- as well as the issuance of preferred shares with a nominal redemption amount and subject to a price adjustment clause. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...

Accordingly, AB Trust will transfer the AB Property (utilizing the s. 97(2) rollover) to an LP (AB LP) formed by it (as general partner) and the Trust (as limited partner), in consideration for the issuance of GP units and the assumption of the AB Trust Notes, which then will be repaid by AB LP by way of set-off against the subscription price by the Trust for LP units. ...

The summary states: No cash consideration or other proceeds of disposition will be received by the unitholders in respect of the diminishment of their rights as a consequence of the amendments. ...

Proposed transactions US Parent Co will transfer its limited partnership interest in Can LP to US Sub (a wholly-owned LLC that has elected to be a corporation for Code purposes and apparently will not hold significant other assets) for fair market consideration consisting of an interest-bearing Promissory Note and shares of US Sub. ...

2013 Ruling 2013-0490341R3- No-type of property spin-off butterfly-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) post butterfly FX loan by TC to DC Preliminary/butterfly reorg The shareholders of Old Pubco (a Canadian public corporation dealing at arm's length with each shareholder) will transfer all their Old Pubco common shares to a newly-incorporated Canadian subsidiary of Old Pubco (New Pubco) in consideration for New Pubco common shares. ...

Transactions Opco will transfer the Property to LP in consideration for units of LP, with LP then managing and developing the Property. ...

Transactions Opco will transfer the Property to LP in consideration for units of LP, with LP then managing and developing the Property. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Dutch cooperative whose articles limited member liability was a corp Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Netherlands cooperative (Dutch Co-op, or "DC"), in consideration for a credit to the membership accounts of the contributing foreign affiliates, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2. ...