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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. ...

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. ...

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 ...

Essentially, the issue in respect of the particular case here under consideration is the date at which the seller and buyer intended that title to the equipment passed to the buyer, having regard to the fact that the equipment was not in existence on the date the agreement of sale was entered into, but was to be (and was) subsequently manufactured by the seller. ... It is submitted that in the case here under consideration, 24(1) So far as we can determine from the materials you provided to us, 24(1) Variation in Exchange Rate Before Date of Acquisition So far as we have been able to determine, there is no case law or statutory guidance as to the treatment of variations in the exchange rate before the date of acquisition of the property. ...

In general terms, where an individual disposes of shares of a subject corporation, within the meaning of subsection 84.1(1), to another corporation with which the individual does not deal at arm's length for consideration comprised only of cash and debt of the other corporation and, immediately after the disposition, the subject corporation would be connected with the other corporation, paragraph 84.1(1)(b) applies to deem the individual to have received a divided equal to the amount by which the value of the non-share consideration received from the other corporation exceeds the paid-up capital of the transferred shares of the subject corporation. ...

On XXXXXXXXXX, Opco 2 acquired the business assets of a XXXXXXXXXX for cash consideration of $XXXXXXXXXX. On XXXXXXXXXX, Opco 2 acquired the business assets of XXXXXXXXXX for cash consideration of approximately $XXXXXXXXXX. ... As consideration, New Opco will assume certain liabilities and will issue New Opco Common Shares to Old Opco. ...

As consideration therefor, S Co will issue a number of its common shares to S having an aggregate fair market value equal to the aggregate fair market value of all the shares so transferred to S Co. ... As consideration therefor, F Co will issue a number of its common shares to F having an aggregate fair market value equal to the aggregate fair market value of all the shares so transferred to F Co. ... As consideration therefor, TG II will issue a number of its Special C Shares to DE having an aggregate redemption amount and fair market value equal to the aggregate fair market value of all the shares transferred to it by DE. ...

Upon DC’s incorporation, A and C each subscribed for XXXXXXXXXX Common shares of DC for $XXXXXXXXXX cash consideration. 5. ... As consideration for the transfer, Partnership received DC Preferred shares and a non-interest bearing promissory note. ... Each class of Preferred shares has a non-cumulative dividend entitlement computed based on a fixed percentage range of the FMV of the consideration received for the shares when first issued. 14. ...

As consideration for the transfer of the shares of the capital stock of CANCO, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the FMV of the shares of the capital stock of CANCO (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. As consideration for the transfer of the shares of the capital stock of FORCO1, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the FMV of the shares of the capital stock of FORCO1 (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. As consideration for the transfer of the loan receivable from FORCO1, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the principal amount of the loan receivable from FORCO1 (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. ...

No consideration other than the common Shares of Holdco will be received by Parentco on the transfer. ...