Search - consideration

Results 1761 - 1770 of 1907 for consideration
Ruling

2005 Ruling 2005-0134461R3 - Loss utilization

None of the Preferred Shares will be, at any time during the implementation of the proposed transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration, except as described herein. ...
Ruling

2005 Ruling 2005-0118951R3 F - Loss utilization

émises pour une considération qui est ou qui inclut: (a) une obligation telle que celle décrite au sous-alinéa 112(2.4)b)(i), à l'exception d'une telle obligation souscrite par une société liée à NOUCO (autrement que par un droit visé à l'alinéa 251(5)b)) immédiatement avant l'émission des actions; ou (b) tout droit tel que celui décrit au sous-alinéa 112(2.4)b)(ii). 32. ...
Ruling

2016 Ruling 2016-0673141R3 - Loss consolidation involving interco loans

The Newco Preferred Shares will not at any time during the implementation of the Proposed Transactions be: a. the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; b. the subject of a dividend rental arrangement; c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 22. ...
Ruling

2016 Ruling 2016-0643751R3 - Continuance of a XXXXXXXXXX to a XXXXXXXXXX

Should one of the XXXXXXXXXX trigger events occur, as set out in the XXXXXXXXXX, the Class XXXXXXXXXX-Series 1 shares will be immediately cancelled for no consideration and the Stated Capital Account of the Class XXXXXXXXXX- Series 1 shares will immediately be reduced to XXXXXXXXXX. ...
Ruling

2018 Ruling 2017-0681471R3 - Variation of Trust

No Unitholder will be entitled to consideration or proceeds of disposition in respect of his, her or its beneficial interest in the Trust as a result of the Proposed Transactions. 28. ...
Ruling

2018 Ruling 2017-0723421R3 - Creation of a new Mutual Fund Trust

The Trust will subscribe for one unit of Trust 2 for $XXXXXXXXXX consideration. ...
Ruling

30 November 1995 Ruling 9613383 - XXXXXXXXXX TAX SHELTER

The XXXXXXXXXX Partnership will agree with XXXXXXXXXX 7.The XXXXXXXXXX Partnership will agree to prepare XXXXXXXXXX reports that may be reasonably required by XXXXXXXXXX The XXXXXXXXXX Partnership will agree to comply with XXXXXXXXXX XXXXXXXXXX 8.In consideration for providing the XXXXXXXXXX, the XXXXXXXXXX Partnership will be entitled to receive a fee (the "XXXXXXXXXX Fee"). ...
Ruling

30 November 1995 Ruling 9630903 - REORGANIZATION

As sole consideration received as a result of the amalgamation, each of the shareholders of Holdco 1 will receive the same number and type of common shares of XXXXXXXXXX having a fair market value and paid-up capital immediately after the amalgamation equal to the fair market value and paid-up capital, respectively, of the shares of Holdco 1 which they owned immediately before the amalgamation. ...
Ruling

30 November 1996 Ruling 9700343 - mutual fund ltd partnership and matchable expenditures

In consideration of the management services provided by XXXXXXXXXX, the Funds pay management fees calculated as a percentage of the Net Asset Value of the Funds. ...
Ruling

30 November 1996 Ruling 9711803 - TREATY LAND ENTITLEMENT XXXXXXXXXX

XXXXXXXXXX 971180 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX in which you requested us to confirm for the Applicants the rulings we provided in our letter of XXXXXXXXXX, 1997 identified as #964206 (the "Ruling Letter"), taking into consideration the latest version of the relevant agreements as well as various amendments to the description of the facts and proposed transactions in the Ruling Letter. ...

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