Search - consideration

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.” ...

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Canadian Sub-custodian in respect of the property held by the Subfund on behalf of the Pension Fund, including purchase consideration for such property, will be considered an amount paid or credited to the Pension Fund in proportion to its participation in the assets and income of the particular Subfund. ...

Proposed transactions Although all the Fund 1 and Fund 2 properties will continue to be legally and beneficially owned by the Taxpayer, a combination of the two Funds will be effected by the Taxpayer changing the allocation of properties for accounting and administrative purposes, so that all of the properties in Fund 1 will be allocated to Fund 2, with no consideration being paid. ...

On the butterfly distribution, DC transfers Newco to TCo in consideration for preferred shares and the assumption of liabilities, following which there is a cross-cancellation of the shareholdings between DC and TC, so that TC becomes an indirect wholly-owned subsidiary of Foreign Spinco. ...

Following the replacement of those notes and some of the newer debt with amended notes, and the transfer to the unitholders of units of a new fixed investment trust with nominal assets (the “F17 Trust”) in consideration for the nominal cash received by them for the transfer of their units of Finance Trust to the REIT (whose ACB will have been reduced under s. 107.4(3)(l)), the amended notes will be transferred by the REIT under s. 107.4 to the F17 Trust. ...

Proposed transactions under Plan of Arrangement After purchasing for cancellation any common shares of dissenting shareholders, the Taxpayer will transfer the third property to a newly-incorporated subsidiary (“Newco”) in consideration for common shares of Newco (the “Newco Distribution Shares”) equaling in number the number of outstanding common shares of the Taxpayer. ...

Finance Trust will transfer all of the US Holdco Notes held by it (being most of its property) to the REIT for no consideration (the “Disposition”). ...

For the purposes of Part XIII and s. 116, any amount paid or credited by a payer to the sub-custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

Newco will acquire the shares of Holdco for cash consideration funded as described in above, for a note and for Class B non-voting redeemable retractable preferred shares of Holdco (whose paid-up capital is limited in accordance with s. 84.1(1)(a)), with a s. 85(1) election being made. ...

In connection with unwinding the loss consolidation arrangement, Newco will redeem the Newco Preferred Shares held by NewLossco in consideration for a non-interest bearing promissory note (the “Newco Note”), with NewLossco repaying the IB Loan by assigning the Newco Note to Lossco, and with Newco and Lossco will agree to set off the amount due under the NIB Loan against the amount due under the Newco Note. ...