Search - consideration

Results 131 - 140 of 1913 for consideration
Ruling

15 August 1990 Ruling 74801 F - Cape Breton Investment Tax Credit Program

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. ...
Ruling

18 April 1990 Ruling 59403 F - Transfer of Shares to a Canadian Corporation

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. ...
Ruling

2008 Ruling 2007-0247611R3 - Public butterfly reorganization

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. ...
Ruling

2007 Ruling 2007-0233881R3 - XXXXXXXXXX Corporate Reorganization

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. ...
Ruling

2019 Ruling 2019-0795521R3 - XXXXXXXXXX split-up butterfly

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. ...
Ruling

2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover

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. ...
Ruling

2010 Ruling 2009-0343991R3 - Classification of a XXXXXXXXXX Co-op

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

2001 Ruling 2000-0060603 - Merger of XXXXXXXXXX Partnerships

XXXXXXXXXX (Consideration will be given to merging the XXXXXXXXXX Management Partnership and XXXXXXXXXX Management Partnerships at a future time. ... Alternatively, the XXXXXXXXXX Partners will transfer their interests in the XXXXXXXXXX Management Partnership to the XXXXXXXXXX Management Partnership in consideration for partnership interests pursuant to subsection 97(2) of the Act. ... The parties will agree to allocate to each of the XXXXXXXXXX Assets, as consideration therefor, such part of the aggregate consideration to be given by the XXXXXXXXXX Partnership for all the XXXXXXXXXX Assets as is equal to the fair market value of the particular XXXXXXXXXX Asset. 22. ...
Ruling

2000 Ruling 1999-0010743 - PARAGRAPH 85(1)(B)

A will acquire XXXXXXXXXX limited partnership units of the Partnership for a cash consideration of $XXXXXXXXXX. ... As consideration for the transfer of property described herein, the Partnership will: (c) assume the Property Debt; and (d) issue to Mr. ... A's Property Debt having a principal amount equal to the Cash Amount will be assumed by the Partnership as consideration for the transfer by Mr. ...
Ruling

1999 Ruling 9904563 - 164(6) - POST MORTEM PLAN

Also on that date, XXXXXXXXXX also issued XXXXXXXXXX common shares in the name of XXXXXXXXXX for nominal consideration. 10. ... XXXXXXXXXX children will subscribe for the common shares of Newco for nominal consideration 19. ... The Estate will receive XXXXXXXXXX Class A shares and XXXXXXXXXX Class B shares of Newco as consideration for the transfer of its XXXXXXXXXX Class C shares (i.e. total value of consideration equal to $XXXXXXXXXX). ...

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