Search - consideration

Results 1811 - 1820 of 1921 for consideration
Ruling

2001 Ruling 2001-0112713 - PRESCRIBED PHANTOM SHARE PLAN

(t) If the number of outstanding Shares is increased or decreased as a result of a stock split, consolidation or recapitalization and not as a result of the issuance of Shares for additional consideration or by way of stock dividend, the Company will make appropriate adjustments to the number of Units credited to a Member's Unit Account. ...
Ruling

2002 Ruling 2002-0152593 - INCORPORATING A MEDICAL PARTNERSHIP

Immediately before this wind up, the Partnership shall have no assets other than the property received from MedCo as consideration for the sale of the Assets referred to in Paragraph 11. ...
Ruling

2002 Ruling 2002-0159043 - INNOVATIVE INSTRUMENT

The surrender of Trust Securities by a holder thereof to the Trust for Preferred Shares XXXXXXXXXX W upon exercise of the Holder Exchange Right as described above in paragraph 14 will be effected by the Trust: (a) converting $XXXXXXXXXX principal amount of the XXXXXXXXXX Note held by it into XXXXXXXXXX Preferred Shares XXXXXXXXXX W in accordance with the terms thereof as set out below, for each Trust Security so surrendered, and (b) redeeming each Trust Security so surrendered in consideration of the transfer to the holder thereof by the Trust of XXXXXXXXXX Preferred Shares XXXXXXXXXX W. 16. ...
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. ...

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