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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. ...

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. ...

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). ...

As sole consideration therefor, each of TC1 and TC2 will issue the TC1 Note 1 and the TC2 Note 1 to Bco respectively. ... As consideration therefor, TC3, TC4, TC5 and TC6 will issue the TC3 Note 1, the TC4 Note 1, the TC5 Note 1 and the TC6 Note 1 to Cco respectively. ... Paragraph 79 is amended by adding the words “Class D” immediately after the words “Dco will transfer certain Dco Business Assets (the “Dco Business Assets”) to the TCs in consideration for the issuance of TC1, TC2, TC3, TC4, TC5 and TC6”. 21. ...

In consideration, Dco agreed to pay to Aco cash and to make further payments of the purchase price to Aco by way of a participation right (the "Participation Right"). ... In consideration for the purchase, Bco agreed to make to Aco XXXXXXXXXX lump sum payments plus additional payments which are contingent on the level of XXXXXXXXXX production from the Mine exceeding XXXXXXXXXX. 8. ... XXXXXXXXXX of the Assignment and Payment Agreement provides that in consideration for the sale, transfer and assignment of the Participation Right, Cco shall pay to Bco: $XXXXXXXXXX in Canadian currency; and an amount equal to XXXXXXXXXX% of the dollar amount of each Participation Right payment within XXXXXXXXXX business days after receipt of such payment by Cco from Dco. 10. ...

Under the Plan, a transfer of the Options is permitted to the Employee's family members "or other persons or entities" according to such terms as determined by the committee (the "Committee") appointed by the board of Corporation B under the terms of the Plan, provided the Employee receives no consideration for the transfer. 10. ... The Employee will transfer all of the Options to the Corporation for no consideration. ... During the Employee's lifetime, and on or before the expiry date of one or more of the Options (the "Particular Options"), the Corporation will either: (a) exercise the Particular Options and acquire the underlying shares of Corporation B; or (b) transfer the Particular Options to the Employee for no consideration, in which case the Employee will exercise the Particular Options and directly acquire the underlying shares of Corporation B. 16. ...

With respect to issuing refunds of Part XIII tax paid or withheld on payments made for the right to produce or reproduce computer software programs during the period July 1, 1983 to June 8, 1988, we offer the following comments for your consideration.       ... Convention (1980).      21(1)(b)      It should be noted that the time limit for requesting competent authority consideration in Canada's other income tax conventions is different than the limits of the U.S. ... This date approximates the two year time limit found in many of Canada's income tax conventions for requesting competent authority consideration. ...

Accordingly, while it may be argued that, in the circumstances described above, the consideration paid by the corporate investor should be deducted in computing its safe income on the basis that such amounts were paid to obtain a reduction (through a tax credit) in an income tax liability of the corporate investor, you suggest that safe income need not be so reduced because the amounts expended were paid to acquire the property. ... Yours truly, for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch EXHIBIT Calculation of Safe Income Where SRTC property acquired Example Corporate taxpayer that has operating income of $10,000,000 acquires an SRTC property described in subsection 127.3(2)(a)(iii) to (v) of the Act for consideration equal to $4,000,000 and becomes entitled to a tax credit, within the meaning of paragraph 127.3(2)(a) of the Act, equal to $2,000,000.  ... Operating Income   $10,000,000   less- Tax @ 48% $4,800,000    - Tax Credit 2,000,000    - Net Tax $2,800,000 (2,800,000) less Net Outlay for SRTC property not deducted in computing operating income    - Consideration Paid $4,000,000    - Cost (ss. 127.3(6)) 2,000,000    - Net Outlay $2,000,000 (2,000,000) Safe Income on Hand immediately after acquisition of SRTC property   $5,200,000 Gain on Disposition of SRTC property      - Non Taxable Gain (1/3) $100,000    - Taxable Cap. ...

On XXXXXXXXXX, XXXXXXXXXXCo redeemed XXXXXXXXXX class A preferred shares that DC held in XXXXXXXXXXCo in exchange for cash consideration of $XXXXXXXXXX. 21. ... Upon New6XCo's incorporation, 6XCo will subscribe for common shares in New6XCo in exchange for nominal cash consideration. 42. ... Upon New5XCo's incorporation, 5XCo will subscribe for common shares in New5XCo in exchange for nominal cash consideration. ...

On incorporation, Class XXXXXXXXXX common shares of each of Control 5, Control 6 and Control 8, respectively, will be issued to the respective incorporators for nominal consideration. ... In consideration for such transfers, Subco will each issue XXXXXXXXXX Class XXXXXXXXXX preferred shares and assume a pro-rata share of the liabilities of XXXXXXXXXX. ... In consideration for such transfers, the Control Corporations will each issue Class XXXXXXXXXX preferred shares and assume a pro-rata share of the liabilities of XXXXXXXXXX. ...