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Your client will receive consideration for entering into such agreement. 3.      ... You requested our opinion as to whether or not the consideration received with respect to the non-competition agreement would also be considered U.S. source income for purposes of that subsection. ... We agree with your interpretation of section 42 of the act with respect to the tax treatment of the consideration to be received with respect to the non-competition agreement.  ...

No consideration is payable by such third parties under the confidentiality agreements. ... DC does not own the shares of any other corporation. g) Paragraph 15 will be amended by replacing the term "intellectual property" with the defined term "the Intellectual Property". h) The second paragraph of Paragraph 17 will be amended to read as follows: Each TechCo Reorganization Share will be redeemable at any time at the option of the issuer and retractable at any time at the option of the holder for an aggregate amount equal to the fair market value of the property received for the issuance of the shares, net of any liabilities assumed by the issuer at the time of issuance and the value of any other non-share consideration provided by the issuer by virtue of entering into the Facility (as described in Paragraph 44A), divided by the number of TechCo Reorganization Shares issued as consideration for such property. i) The second paragraph of Paragraph 18 will be amended to read as follows: Each PlantCo Reorganization Share will be redeemable at any time at the option of the issuer and retractable at any time at the option of the holder for an aggregate amount equal to the fair market value of the property received for the issuance of the shares, net of any liabilities assumed by the issuer at the time of issuance and the value of any other non-share consideration provided by the issuer by virtue of entering into the Facility (as described in Paragraph 44A), divided by the number of PlantCo Reorganization Shares issued as consideration for such property. j) The fourth sentence in Paragraph 19 will be amended by replacing the words "without nominal or par value" with the words "with nominal par value". k) The following new Paragraph 29A will be added after Paragraph 29: DC will transfer its legal title to (but not beneficial ownership of) PlantC to Aco as bare trustee for no consideration. ... On the subsequent transfer of the beneficial ownership of PlantC by DC to PlantCo as contemplated, a similar bare trust agreement between Aco and PlantCo will be executed. l) The first sentence of Paragraph 33 will use the defined term "the Intellectual Property" rather than "intellectual property". m) The last sentence of the first paragraph of Paragraph 33 will be amended by the following: In consideration for the transfer, TechCo may assume liabilities of DC and may provide non-share consideration to TechCo by virtue of its becoming a party to the Facility (as described in Paragraph 44A) and will issue TechCo Reorganiztion Shares, with an aggregate fair market value and redemption amount equal to the fair market value of the property transferred to TechCo, as described herein, net of any liabilities assumed by TechCo in respect thereof and the value of any non-share consideration provided by TechCo by virtue of TechCo becoming a party to the Facility (the "TechCo Redemption Amount"). n) The first sentence of Paragraph 34 will be amended to refer to beneficial ownership of PlantC and the Fixed Assets, such that the sentence reads: Immediately after the transfer of the DC PlantCo Reorganization Shares to PlantCo, DC will transfer to PlantCo, certain business assets including beneficial ownership of PlantC and related equipment, the Fixed Assets and cash or near-cash property (collectively the "PlantCo Butterflied Assets") such that the net fair market value of each type of property so transferred to PlantCo (after allocating and deducting, in the manner described in Paragraph 16 above, the liabilities of DC that are to be assumed by PlantCo) will approximate the PlantCo Butterfly Proportion of the net fair market value of all of the property of that type owned by DC immediately before the transfer. o) The last sentence of the first paragraph of Paragraph 34 should be amended to read as follows: In consideration for the transfer, PlantCo may assume liabilities of DC and may provide non-share consideration to PlantCo by virtue of its becoming a party to the Facility (as described in Paragraph 44A) and will issue PlantCo Reorganization Shares, with an aggregate fair market value and redemption amount equal to the fair market value of the property transferred to PlantCo, as described herein, net of any liabilities assumed by PlantCo in respect thereof and the value of any non-share consideration provided by PlantCo by virtue of PlantCo becoming a party to the Facility (the "PlantCo Redemption Amount"). p) The first sentence of Paragraph 44 will be amended as follows: Parent will transfer its DC New Common Shares to Blocker for shares of Blocker having a fair market value not exceeding the value of the DC New Common Shares so transferred. q) The following two Paragraphs will be added after Paragraph 44. 44A. ...

Holdco will not receive any non-share consideration on the transfer of the DC shares. 50. ... DC will not receive any non-share consideration on the transfer of the Landco1 shares. 53. ... DC will not receive any non-share consideration on the transfer of the Landco3 shares. ...

The majority of the shares of Target was acquired for cash consideration by Parent Acquisitionco, while the remaining shares of Target were acquired by Parent directly in consideration for shares of Parent. ... The redemption value of a Newco Preferred Share was equal to the FMV of any property received in consideration for its issuance less any consideration received for subsequent reductions of PUC in respect of the share. ... The balance of the consideration for the XXXXXXXXXX Rights was paid in cash. ...

Aco will subscribe for XXXXXXXXXX common shares for Fco for consideration of $XXXXXXXXXX. ... Fco will redeem its preferred shares held by Bco for their redemption value and will issue a promissory note as consideration. Bco will redeem its common shares held by Fco for their redemption value and will issue a promissory note as consideration. ...

There is no requirement that the consideration given to a resource expenditures.  The consideration for which the Shares are issued will be valued at it fair market value at that time. ... If the value of the property is $1,000, the consideration given for the flow-through shore agreement with the issuing corporation would renounce resource expenditures to the taxpayer in an amount equal to $1,000. ...

Each year some of the employees of Corporation A are offered non-voting common shares of Corporation B for no consideration. ... the transaction was a gift for no consideration or a transaction between the employer and employees for consideration (i.e.- for services rendered). Generally, transactions between an employer and arm's length employees occur by virtue of their employment and are for consideration (i.e.- they are not gifts). ...

19 September 1991 Ruling 91M09121 F- Dividends and Section 160 Unedited CRA Tags 160(1)(e)(i) QUESTION 48- DIVIDENDS AND SECTION 160 QUESTION Under subparagraph 160(1)(e)(i) of the Act, a non-arm's length transferee of property may be liable jointly with the transferor  and is limited to the amount by which the value of the transferred  property exceeds the value of any consideration given for the property.  ... Does Revenue Canada agree that for the purposes of subparagraph 160(1)(e)(i) of the Act (a)  the declaration of the dividend does not constitute a  transfer of property, and (b)  the extinguishment of the corporate debt on payment of the dividend constitutes valuable consideration given for the dividend? ... The purpose of this paragraph to prevent a person with substantial income tax liability from defeating the claims made on him by transferring his property to any non-arm's length party at less than fair market value consideration. ...

"Newco Redemption Amount" means the FMV of the property that DC will assign to Newco in consideration for XXXXXXXXXX class A preferred shares in Newco less the consideration other than shares, if any, to be issued to DC as further described in Paragraph 25 divided by the number of class A preferred shares issued as consideration for the transferred property. ... Immediately thereafter, DC will proceed with the XXXXXXXXXX Sale in consideration for cash. 13. ... On XXXXXXXXXX, Newco will redeem the XXXXXXXXXX class A preferred shares that DC will hold in Newco in consideration for Promissory Note 2. ...

TargetSub XXXXXXXXXX transferred its net assets to CarveOut XXXXXXXXXX, on a taxable basis, in consideration for cash. ... CarveOut XXXXXXXXXX acquired inter-company debt owing by CarveOut XXXXXXXXXX in consideration for the issuance by CarveOut XXXXXXXXXX of four demand promissory notes as follows: 65.1 CarveOut XXXXXXXXXX Note 2 issued to TargetSub XXXXXXXXXX as consideration for debt owing to TargetSub XXXXXXXXXX; 65.2 CarveOut XXXXXXXXXX Note 3 issued to TargetSub USA as consideration for debt owing to TargetSub USA; 65.3 CarveOut XXXXXXXXXX Note 4 issued to TargetSub USA as consideration for debt owing to TargetSub USA; 65.4 CarveOut XXXXXXXXXX Note 5 issued to TargetSub XXXXXXXXXX as consideration for debt owing to TargetSub XXXXXXXXXX. 66. ... Buyerco subscribed for XXXXXXXXXX common shares of the capital stock of Bidco in consideration for $XXXXXXXXXX. 130. ...