Search - consideration
Results 291 - 300 of 334 for consideration
Ruling summary
2021 Ruling 2021-0877011R3 - Post-mortem Hybrid Pipeline -- summary under Subsection 84(2)
The estate will transfer, to a “Newco” formed by it under the CBCA, Class A preferred shares of Holdco in consideration for a demand note ("Note 2") of Newco and a Class A share of Newco (apparently, its only issued and outstanding share), electing under s. 85(1). ...
Ruling summary
2022 Ruling 2021-0904611R3 F - Corporate reorganization and trust to trust transfer -- summary under Paragraph (g)
Fco makes a PUC distribution to the trust by distributing a note of a subsidiary in an amount sufficient for the trust to pay the tax on the above taxable dividend. the father of CC4 settles a new trust for the exclusive benefit of CC4, with the old trust transferring its Class Z shares of Fco to the new trust for no consideration, and with the new trust not electing out of the application of para. ...
Ruling summary
2021 Ruling 2021-0907591R3 F - Post-mortem Pipeline -- summary under Subsection 84(2)
Proposed transactions The estate will transfer to a corporation newly incorporated by it (Newco) its Class A and Class B shares of Holdco in consideration for Note 1 (plus some Newco Class A voting and participating shares) and Note 2 (plus some Newco Class B voting redeemable preferred shares), respectively, electing under s. 85(1). ...
Ruling summary
2021 Ruling 2019-0800191R3 - Carrying on business in Canada. -- summary under Paragraph 2(3)(b)
Pursuant to a new services agreement with Foreignco, Canco will provide “Computer Services” and “Other Support Services” to Foreignco and other non-resident members of the group in consideration for reasonable fees. ...
Ruling summary
2023 Ruling 2023-0973911R3 - Loss Consolidation Ruling -- summary under Paragraph 111(1)(a)
Numberco will redeem its preferred shares in consideration for assigning the non-interest-bearing note to Profitco, which will then be set-off against the IB Note. ...
Ruling summary
2023 Ruling 2023-0986521R3 F - 104(4) and Pipeline -- summary under Subsection 84(2)
Following the realization by Trust 1 of gain pursuant to s. 104(4)(b)(ii) on the subject shares, it will dispose of the Subject Shares to Holdco 1 in consideration for Notes 1, 2 and 3 of Holdco 1. ...
Ruling summary
2014 Ruling 2014-0547491R3 - REIT entering into new LP -- summary under Real Estate Investment Trust
Development and financing Pursuant to a Development Agreement with New LP, Developer Partner will develop the property in consideration for stipulated fees and "DevCorp" will provide development administrative services to New LP for fees. ...
Ruling summary
2014 Ruling 2014-0518451R3 - Loss consolidation -- summary under Paragraph 111(1)(a)
After generation of the requisite losses in Aco, Newco will redeem the Newco Preferred Shares of ACo in consideration for the Newco Note. ...
Ruling summary
2014 Ruling 2013-0511991R3 - Loss consolidation -- summary under Paragraph 111(1)(a)
The unwinding of the transactions will be accomplished by: Newco redeeming the Newco Preferred Shares held by ACo in consideration for a non-interest bearing promissory note (the "Newco Note"); ACo will repaying Loan 1 by assigning the Newco Note to Lossco; and Loan 2 and the Newco Note being set-off. ...
Ruling summary
2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up -- summary under Subsection 80.01(4)
Approximately XX months after 1 above, Canco3 will sell to a newly-incorporated subsidiary of Canco1 ("New ULC") the Notes B and the Canco1 Note B in consideration for a demand non-interest bearing Canadian-dollar note of New ULC (the "Note C"). ...