Search - consideration

Results 151 - 160 of 1921 for consideration
Ruling

2023 Ruling 2022-0957571R3 - Cross-Border Butterfly

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. ...
Ruling

2007 Ruling 2006-0212481R3 - Reorganization of a mutual fund trust

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. ...
Ruling

2006 Ruling 2005-0162951R3 - Single-wing butterfly

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. ...
Ruling

2001 Ruling 2000-0044193 - XXXXXXXXXX - Butterfly

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. ...
Ruling

30 November 1996 Ruling 9719633 - COST OF BORROWING

The shareholders of XXXXXXXXXX exchanged their shares for a combination of new Class XXXXXXXXXX Shares, Class XXXXXXXXXX Shares, and Class XXXXXXXXXX Shares of XXXXXXXXXX. 11.On XXXXXXXXXX, immediately following the amalgamation and share exchange to form XXXXXXXXXX, a wholly owned subsidiary of Canholdco, XXXXXXXXXX (“Acquisition Co.”) acquired all of the outstanding Class XXXXXXXXXX Shares of XXXXXXXXXX from the public shareholders for cash consideration of $XXXXXXXXXX. 12.Also on XXXXXXXXXX, Acquisition Co. subscribed for XXXXXXXXXX common shares of XXXXXXXXXX for cash consideration of $XXXXXXXXXX. ... The full amount of $XXXXXXXXXX was added to the stated capital account of Canholdco. 14.On XXXXXXXXXX, as a result of the transactions in paragraphs 11 and 13, Acquisition Co. acquired control of XXXXXXXXXX. 15.The total cash consideration of $XXXXXXXXXX paid by Acquisition Co. to acquire control of XXXXXXXXXX was the result of a subscription by Canholdco for XXXXXXXXXX fully paid common shares of Acquisition Co. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Ruling

1999 Ruling 9931713 - PARTNERSHIP REORGANIZATION

Newco will then rent the depreciable property to XXXXXXXXXX for fair market value consideration. 15. ... After the completion of the transaction described in paragraph 15 above and on or after XXXXXXXXXX will dispose of its XXXXXXXXXX% partnership interest in XXXXXXXXXX and of its XXXXXXXXXX% interest in XXXXXXXXXX in favour of XXXXXXXXXX for an arm's length cash consideration. 17. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Ruling

28 December 1989 Ruling 58491 F - Fund Raising Activities of Charitable Organizations

In consideration for the capital contribution, the charity undertakes to pay the donor a specified amount of the donor.  ... You mention that the consideration for the issue of an annuity would be the lesser of the capital contribution and the amount that would be charged by a commercial annuity issuer.  ... Moreover, if we refuse to regard any part of the donor's payment as the gift because the donor receives as consideration for annuity payments. it follows that the cost of the annuity is not less than the payment to the charity.  ...
Ruling

2012 Ruling 2011-0425211R3 - Reduction of capital

Since XXXXXXXXXX, Pubco has made advances of: (a) $XXXXXXXXXX to FA 1 in consideration for a promissory note issued by FA 1 to Pubco in the principal amount of $XXXXXXXXXX (“FA 1 Note 2”), and (b) $XXXXXXXXXX to FA 2 in consideration for a promissory note issued by FA 2 to Pubco in the principal amount of $XXXXXXXXXX (“FA 2 Note 2”). ... Canco1 will loan the subscription proceeds of $XXXXXXXXXX, as described in Paragraph 19, to FA 3 in consideration for a promissory note issued by FA 3 to Canco 1 in the principal amount of $XXXXXXXXXX. 21. ... Canco 2 will loan the subscription proceeds of $XXXXXXXXXX, as described in Paragraph 25, to FA 2 in consideration for a promissory note issued by FA 2 to Canco 2 in the principal amount of $XXXXXXXXXX. 27. ...
Ruling

2014 Ruling 2013-0503611R3 - Post-Mortem Planning

Spousal Trust subscribed for XXXXXXXXXX Class "B" Shares for a consideration of $XXXXXXXXXX. ... Trust C owns 1 common share of the capital stock of Newco which has been subscribed for a consideration of $XXXXXXXXXX. ... Trust D will subscribe for 1 common share of the capital stock of Newco for a consideration of $XXXXXXXXXX. 29. ...
Ruling

2001 Ruling 2001-0082843 - Paragraph 55(3)(a) spin-off

The total consideration in respect of these purchases amounted to $XXXXXXXXXX. ... No other consideration will be received by Bco in respect of the conversion. 32. ... No other consideration will be received by Bco in respect of the conversion. 43. ...

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