Search - consideration

Results 121 - 130 of 1913 for consideration
Ruling

2005 Ruling 2004-0104851R3 - Single-wing Spilt-up Butterfly

As consideration for the transfer of the DC-Sub-2 Pubco Shares, Subco will issue XXXXXXXXXX common shares. ... DC-Sub-1 and DC-Sub-2 will each only receive cash from the third party as consideration therefor. ... None of the Transferee2-Sub Preferred Shares will be issued for consideration that includes a taxable preferred share. 22. ...
Ruling

2002 Ruling 2002-0118973 - Internal Reorganization

On XXXXXXXXXX, Exchangeco issued an additional XXXXXXXXXX Exchangeco Class A Shares to Foreignco in consideration for $XXXXXXXXXX. 17. ... Cco will, as consideration for the subscription, issue to ACO-US notes with a fair market value equal to the fair market value of the subscribed shares. ... DCO will transfer to NSULC all of the DCO-US Shares in consideration for NSULC Class B Shares with a fair market value equal to the fair market value of the DCO-US Shares so transferred. ...
Ruling

2008 Ruling 2008-0279671R3 - Partnership Wind-up

The agreement will also state that the partnership will transfer particular assets to the partners as consideration for their assumption of the partnership's "Deferred Revenue" liabilities. ... The consideration given by the Trust for these shares was less than $XXXXXXXX. ... The Partnership will transfer certain of its assets to Newco, in consideration for additional common shares of Newco, and Newco's assumption of the Partnership's bank liabilities. ...
Ruling

2016 Ruling 2015-0608841R3 - 55(3)(a) spin-off

The consideration received by FamCo will be a promissory note (“Promissory Note #1”) payable by Child 3 to FamCo. ... As consideration for the transfer, Newco1 will issue XXXXXXXXXX Class E shares to Mr. ... As consideration for the transfer, Newco2 will issue XXXXXXXXXX Class E shares to Mrs. ...
Ruling

2001 Ruling 2000-0053013 - Loss Consolidation

As consideration for such transfer, Subco2 issued XXXXXXXXXX of its common shares and paid non-share consideration of $XXXXXXXXXX for an aggregate FMV of $XXXXXXXXXX. ... As consideration for such share redemption, Subco2 issued to Subco4 a demand promissory note ("Subco2 Promissory Note") with a principal amount and FMV of $XXXXXXXXXX bearing an interest rate at XXXXXXXXXX% per annum. ... As sole consideration for such transfer, Subco1 will issue to Pubco (a) XXXXXXXXXX Subco1 Class B Common Shares; and (b) XXXXXXXXXX Subco1 Preferred Shares I having an aggregate redemption and retraction amount equal to $XXXXXXXXXX. ...
Ruling

2002 Ruling 2001-0097463 - Divisive Reorganization

The Debt was issued as consideration for Mr. A's acquisition of certain common shares of Holdco. 2. ... A will subscribe for XXXXXXXXXX Holdco New Commons for nominal consideration. 17. ... Holdco will transfer the Target Preferred Shares to New Opco in consideration for XXXXXXXXXX New Opco Common Shares. ...
Ruling

2008 Ruling 2008-0275441R3 - Supplemental Ruling

Capitalized terms not defined herein are as defined in the Letter. 1) Redemption of shares of the capital stock of NewSubco You advised us that, contrary to what was contemplated in Paragraph 64 of the Letter, the XXXXXXXXXX redeemable XXXXXXXXXX shares of the capital stock of NewSubco owned by TargetSubco III have already been redeemed for FMV consideration XXXXXXXXXX. 2) Redemption of the XXXXXXXXXX shares, XXXXXXXXXX, of the capital stock of XXXXXXXXXX You advised us that, contrary to what was contemplated in Paragraph 55 of the Letter, the XXXXXXXXXX shares, XXXXXXXXXX, of the capital stock of Target will not be redeemed. Rather, the XXXXXXXXXX shares, XXXXXXXXXX, of the capital stock of Amalco II (XXXXXXXXXX) will be redeemed for cash consideration after the date on which the XXXXXXXXXX will be effective. ...
Ruling

2005 Ruling 2005-0163131R3 - Supplemental Ruling - 2005-012598

As a result of your letter, the following amendments are made to the Ruling: The first two sentences of Paragraph 30(ii) of the Ruling are changed to read as follows: Amalco I will transfer all of the issued and outstanding shares of the capital stock of Target Opco to Buyerco for FMV consideration. The consideration for this transfer will be paid in full by Buyerco by the issuance to Amalco I of redeemable and retractable preferred shares, and common shares. ...
Ruling

10 August 2000 Ruling 2000-0030793 - UK PPS Pension Plan

In our opinion, this will only occur where contributions have been made to the foreign plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee or, in some cases, where amounts have been contributed by a government. ... An annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services. ...
Ruling

28 June 1989 Ruling 74013 F - Non-Arm's Length Sale of Shares

We also offer a number of suggested changes for your consideration. These are summarized below and are also written on the draft. 1.      ... In the second sentence in paragraph 3 we suggest "residents of Canada" read "resident in Canada" as that is how the phrase is used throughout the Act. 4.     Consideration ...

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