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Results 301 - 310 of 339 for consideration

2025 Ruling 2025-1052291R3 F - Post-mortem Hybrid Pipeline -- summary under Subsection 84(2)

After the expiry of 12 months, Newco will reduce the PUC of its common shares by an amount equal to the PUC of such shares, in consideration for the issuance to the estate of eight non-interest-bearing notes. ...

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. ...

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. ...

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. ...

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"). ...

2013 Ruling 2012-0472291R3 - Loss consolidation -- summary under Paragraph 111(1)(a)

Immediately following the interest payment in 8, and in connection with the unwinding of the loss consolidation arrangement Newco will redeem the Newco Preferred Shares held by A Co in consideration for its issuance of a non-interest bearing promissory note (the "Newco Note"), then; A Co will repay Loan 2 by assigning the Newco Note to Lossco, then; Loan 3 and the Newco Note will be repaid by mutual set-off. ...

2012 Ruling 2011-0431101R3 - Cross-border spin-off butterfly -- summary under Permitted Exchange

Permitted exchanges/Three-Party Share Exchange Foreign Sub 1 will concurrently make the following transfers of its shares of DC: (i) transfer all the DC Special Shares to TC, a newly-incorporated private corporation subsidiary of Foreign Sub 1 (para. 126(a)) in consideration for the issue of common shares of TC; and (ii) transfer all the DC New Common Shares to Foreign Sub 15, a newly-incorporated LLC subsidiary of Foreign Spinco 1 which, in turn will be a non-Canadian subsidiary of Foreign Sub 1 (para. 126(b)). ...

2016 Ruling 2015-0606771R3 - Disclaimer of trust interest -- summary under Subsection 107(2)

B and there are residual assets) for no consideration. They will make no direction regarding who is entitled to receive the benefit from disclaiming their interest. ...

2016 Ruling 2015-0617351R3 - payments under a German profit transfer agrmt “PTA" -- summary under Subsection 90(2)

FA2 will transfer all of its shares of FA5 to New FA3 in consideration for shares of New FA3. ...

2016 Ruling 2015-0614081R3 - Flow through shares - farm-out agreement -- summary under Subsection 66(12.71)

Proposed transactions Bco will purchase Aco’s interest in Property 1 and Property 2 (being mining claims) in consideration for the reduction of the intercompany debt owing by Aco to Bco, with Aco including the proceeds of disposition in element F of the definition of “cumulative Canadian development expense.” ...

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