Search - consideration

Use of terminal loss to bump elected amount As part of the spin-off transactions, Subco will transfer the Property to Newco in consideration for the assumption of liabilities and the issuance of redeemable Newco Preferred shares. ...

With the consent of the Pensioners, the non-resident “Parent” (which actually appears to be an Opco grandparent) assumes these “SERP Obligations” for no consideration. ...

GP II will sell its undivided interest in each property to Partnership for fair market value consideration and then will be wound up. ​​​​​​​ ...

Transactions Amalco MFC will transfer all of its assets to the Fund in consideration for the assumption of its liabilities and the Fund’s agreement to issue Fund Units to the holders of the Amalco MFC Class A and B Shares in satisfaction of the redemption price for their shares (see 2 below), with a joint s. 132.2 election being made in due course. ...

It was proposed that the acquisition by CanSub2 of the ForSub1 shares be followed by their s. 85.1(3) drop-down to a foreign subsidiary of CanSub2 in consideration for common shares of equivalent value. ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1)(e.3) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e.3) purchaser could acquire Lossco’s business through a sub LP and then acquire Lossco, accessing s. 88(1)(e.3) A foreign-owned Canadian-resident corporation (“Taxpayer”) used a subsidiary LP to acquire the sole business of a “Lossco” that was in CCAA proceedings and then, a number of years later (and perhaps well after the completion of the CCAA restructuring) it purchases the shares of Lossco for nominal consideration and winds up Lossco. ...

The former partners or companies related to them enter into contractual arrangement with a newly-incorporated operating company whereby it will be able to utilize goodwill and related assets of the corporation in consideration for paying a licensing fee and also retaining the former partners for agreed-upon per diem fees. ...

For foreign income tax reasons, MCo is precluded from a direct method of leveraging, namely, incorporating a wholly-owned subsidiary ("OCo"), and transferring its NCo shares to OCo for an interest bearing loan and share consideration and having NCo and OCo amalgamate. ...

2016 Ruling 2016-0630761R3- Transfer of Shares-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) stated capital distribution from FA treated as pre-acq dividend A foreign affiliate (New FA) of a Canadian corporation (ACo) transferred all the shares of FA1 to a Canadian-resident subsidiary (BCo) of ACo in consideration for a note of BCo whose amount equalled the sum of the relevant cost base of the FA1 shares and the net surplus (being exempt surplus) of FA1 (such sum, the “Transfer Amount”). ...

2016 Ruling 2016-0630761R3- Transfer of Shares-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no conferral of benefit where CRA required sideways transfer to occur at less than FMV A foreign affiliate (New FA) of a Canadian corporation (ACo) transferred all the shares of FA1 to a Canadian-resident subsidiary (BCo) of ACo in consideration for a note of BCo whose amount equalled the sum of the relevant cost base of the FA1 shares and the net surplus (being exempt surplus) of FA1 (such sum, the “Transfer Amount”). ...