Search - consideration

Results 1801 - 1810 of 1907 for consideration
Ruling

2003 Ruling 2002-0177363 - Loss Utilization in a Related Group

None of the issued shares referred to herein (including the shares to be issued as described in the Proposed Transactions) are or 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 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). 21. ...
Ruling

2002 Ruling 2002-016729A - Exploration/Sink Shaft-CEE

X Co. acquired the Property from Y Co. in XXXXXXXXXX for consideration comprised of $XXXXXXXXXX. ...
Ruling

2003 Ruling 2002-0177993 - Safe Income Extraction

However, Canco will not be indemnified against commercial risks and will be subject to market considerations subsequent to its acquisition of the shares of the Newcos and the proposed resale of the Pubco shares. 21. ...
Ruling

2017 Ruling 2015-0605161R3 - Fonds commun de placement (FCP) - Luxembourg

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Sub-Custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...
Ruling

2000 Ruling 2000-0018113 - Partial butterfly

In consideration for the transfers described in paragraph 14 above, HoldcoK, HoldcoL and HoldcoM will each issue that number of preferred shares of its capital stock to Amalco having an aggregate fair market value and redemption amount equal to the aggregate fair market value of the property acquired by HoldcoK, HoldcoL and HoldcoM, respectively. 16. ...
Ruling

1999 Ruling 9906993 F - NRO PURCHASES RELATED CO'S DEBT FROM BANK

Le même jour, Mère #3 a transféré une partie de ces biens à Filiale pour une considération de XXXXXXXXXX $, soit le prix payé au tiers pour cette partie des biens. 4.7 Le XXXXXXXXXX, Mère #3 a emprunté XXXXXXXXXX $, auprès deXXXXXXXXXX afin de financer partiellement l'acquisition des biens d'entreprise mentionnés au paragraphe 4.6 ci-dessus. 5. ...
Ruling

2000 Ruling 2000-0034813 - Partnership Reorganization

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 9929533 - PHANTOM STOCK, DIRECTORS PLAN

If the Company issues Common Shares as aforesaid, such Common Shares will be issued in consideration for the past services of the Eligible Director to the Company and the entitlement of the Eligible Director under this Plan shall be satisfied in full by such issuance of the Common Shares. ...
Ruling

2001 Ruling 2000-0061203 - INCORPORATE PARTNERSHIP

Provided that the Partnership winds up its affairs within 60 days from the date of the transfer of Assets (described in paragraph 3 of the Facts) immediately before the winding-up there was no Partnership property other than money or property received from Newco as consideration for the disposition, the provisions of paragraphs 85(3)(d) to (h) of the Act will apply. ...
Ruling

30 June 1999 Ruling 9908430 - CALU CONFERENCE MAY 1999

Absent other considerations, the normal rules for a corporation acquiring a life insurance policy would apply, that is, the premiums would not be deductible and the proceeds received on death would not be included in income. ...

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