Search - consideration

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. ...

The initial Foreign Spinco XXXXXXXXXX was issued to Forco 3 for consideration of USD$XXXXXXXXXX. ... On incorporation, Foreign Spinco subscribed for XXXXXXXXXX TC Common Shares for an aggregate consideration of $XXXXXXXXXX. ... On XXXXXXXXXX, DC subscribed for Partnerco Common Shares for an aggregate consideration of $XXXXXXXXXX. 116. ...

The Fund will subscribe for that number of Class A Shares of Newco as is equal to the number of its issued and outstanding Fund Units (other than those held by designated beneficiaries) in consideration for a cash payment of $XXXXXXXXXX per Class A Share (the "Class A Share Subscription Proceeds"). 29. The Fund will subscribe for that number of TRUST Special Units as is equal to the number of its issued and outstanding Fund Units (other than those held by designated beneficiaries) plus $XXXXXXXXXX in consideration for a cash payment of $XXXXXXXXXX per TRUST Special Unit. 30. ... No consideration other than TRUST Special Units will be received by the Fund Unitholders on the redemption of the Class A Shares and no consideration other than TRUST Ordinary Units will be received by TRUST on the redemption of the Class B Shares. 37. ...

None of the Class B Shares of TC will be issued for consideration that includes a taxable preferred share. One common share of TC will be issued to Individual2 for nominal consideration on incorporation. 16. ... As consideration therefor, TC will issue a non-interest bearing demand promissory note to DC (the "TC Note") having a principal amount and FMV equal to the aggregate Redemption Amount and FMV of the Class B Shares so redeemed by TC. ...

As the sole consideration for the transfer, Transferee 1 will issue common shares to Shareholder 1. ... As the sole consideration for the transfer, Transferee 2 will issue common shares to Shareholder 2. ... As the sole consideration for the transfer, Transferee 3 will issue common shares to Shareholder 3. ...