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Ruling summary

2019 Ruling 2019-0809581R3 - Leveraged Buyout of Public Company -- summary under Subsection 84(2)

Proposed transactions The Continuing Shareholders and key employees will transfer their Pubco Shares to newly-incorporated Newco under s. 85(1) in consideration for common shares (or common shares and notes, in the case of the key employees). ...
Ruling summary

2019 Ruling 2019-0835131R3 F - Post-mortem Pipeline -- summary under Subsection 84(2)

The estate will transfer to a newly-incorporated corporation (“Newco”) its Class E shares of Holdco in consideration for Class A voting participating shares of Newco, electing under s. 85(1) (no price-adjustment clause). ...
Ruling summary

2021 Ruling 2019-0800431R3 - Alter Ego Post-mortem Pipeline and Bump Planning -- summary under Subsection 84(2)

AE Trust will transfer its common shares of Aco and Bco on a s. 85(1) rollover basis to a corporation newly-incorporated by it (Newco) in consideration for two notes of Newco and preferred shares whose redemption value is nominal subject to the operation of a price adjustment clause. ...
Ruling summary

2021 Ruling 2021-0906111R3 - XXXXXXXXXX Post-mortem Pipeline -- summary under Subsection 84(2)

Proposed transactions The Trust will transfer its ACo common shares to a resident corporation newly-formed by it (“Newco”) in consideration for notes and Newco preferred shares, electing under s. 85(1). ...
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. ...

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