Search - consideration
Results 181 - 190 of 1913 for consideration
Ruling
2022 Ruling 2022-0933091R3 - Single-Wing Split-Up Butterfly
Each Class A Special Share will be redeemable and retractable at an amount equal to the FMV of the property acquired in exchange for the share less the non-share consideration given (plus any declared but unpaid dividends thereon), subject to a price adjustment clause. ... As consideration, TC will issue the TC Redemption Note having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class A Special Shares so redeemed by it. ... As consideration, DC will issue to TC the DC Non-CDA Purchase Note having a principal amount and FMV equal to the aggregate FMV of such Common Shares and Class "C" Preference Shares purchased for cancellation. ...
Ruling
2014 Ruling 2012-0432441R3 - Butterfly reorganization
The class F preferred shares are redeemable and retractable for a redemption amount equal to the FMV of the consideration for which they were issued. ... "Promissory Note 1" means the non-interest-bearing promissory note that Newco will issue to DC in consideration for the redemption of the class F preferred to be issued to DC in partial consideration for the Distribution as further described in Paragraph 21. ... Immediately after the Distribution, Newco will redeem all of the class F preferred shares held by DC in consideration for Promissory Note 1. ...
Ruling
2013 Ruling 2013-0507291R3 - Supplemental Ruling
The units of itself that REIT #1 shall receive, as described in 51 above, will be cancelled for no consideration. 53. ... The units of itself that REIT #1 shall receive, as described in 62 above, will be cancelled for no consideration. 64. ... The units of itself that REIT #1 shall receive, as described in 73 above, will be cancelled for no consideration. 75. ...
Ruling
2015 Ruling 2014-0552871R3 - Split-Up Butterfly
Shareholder2 used the consideration received on the sale of the shares of Canco1 to repay its existing indebtedness to DC in the approximate amount of $XXXXXXXXXX. ... TC2 will acquire from TC1, the part of the Collectibles owned by TC1 for FMV consideration which the TCs have determined to be $XXXXXXXXXX plus tax. 58. ... TC1 will acquire from TC2 its interest in the Canco1 Loan Note for FMV consideration which the TCs have determined to be $XXXXXXXXXX. ...
Ruling
2006 Ruling 2006-0195411R3 - Income Trust Reorganization
HOLDCO will settle all inter-company accounts and will dispose of its net current assets and liabilities, with the exception of the HOLDCO notes, to AMALCOA for fair market value consideration. ... The FUND will incorporate MFC by subscribing for one MFC Common Share for nominal consideration. ... In accordance with the Securities Document, the FUND will subscribe for a number of MFC Class A Shares equal to the number of FUND Units then outstanding for nominal cash consideration to be determined at a future date. ...
Ruling
2005 Ruling 2004-0093021R3 - Split-up Butterfly
Opco will subscribe for XXXXXXXXXX New Opco Common Shares for a total consideration of $XXXXXXXXXX. ... As consideration for the transfer, Interco will either issue additional shares to Opco or non-share consideration. 47. ... Dco will subscribe for XXXXXXXXXX Dco2 Common Shares for a total consideration of $XXXXXXXXXX. ...
Ruling
1999 Ruling 9901513 - BUTTERFLY REORGANIZATION
On incorporation, one class A common share will be issued to XXXXXXXXXX for consideration of U.S. ... The liabilities assumed by the Transferee Corporations will be assumed as consideration for particular properties. ... The interest rate on the Excess Notes will exceed the rate of interest on the debt assumed as consideration for these issues. 44. ...
Ruling
1999 Ruling 9917383 - REORGANIZATION
XXXXXXXXXX will not receive any consideration for these transfers. The purpose of these transactions is to comply with XXXXXXXXXX land transfer tax requirements with respect to the transfers of the properties. 27. ... As consideration for the transfer, XXXXXXXXXX Holdings will give XXXXXXXXXX Trustco the sum of $XXXXXXXXXX. 29. ... As consideration for the transfer, XXXXXXXXXX Holdings will give XXXXXXXXXX Trustco the sum of $XXXXXXXXXX. 30. ...
Ruling
2019 Ruling 2019-0811641R3 - Multi-wing split up butterfly
In particular, Sibling 1 will transfer his XXXXXXXXXX common shares of DC to TC1 in exchange for TC1 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred; Sibling 2 will transfer his XXXXXXXXXX common shares of DC to TC2 in exchange for TC2 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred; and Sibling 3 will transfer her XXXXXXXXXX common shares of DC to TC3 in exchange for TC3 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC so transferred. ... For greater certainty, there will be no non-share consideration on the transfer of DC Sub shares. 38. ... The agreed amount in respect of the shares of DC Sub so transferred will not be greater than their FMV nor will it be less than the FMV, at the time of disposition, of the non-share consideration received as consideration. ...
Ruling
2023 Ruling 2022-0958241R3 - Public Spin-Off Butterfly
Each holder of DC Equity Incentive Securities will dispose of such holder’s Butterfly Proportion thereof to SpinCo in consideration for corresponding SpinCo Equity Incentive Securities, and will dispose of the remaining portion thereof to DC in consideration for corresponding DC New Equity Incentive Securities. ... Every Participant will receive FMV consideration from SpinCo in the form of one SpinCo Common Share for every transferred DC Preference Share. ... DC will redeem for cancellation all of the outstanding DC Preference Shares held by SpinCo and will issue to SpinCo, as sole consideration therefor, the DC Redemption Note. ...