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The persons elected as directors and appointed as officers of F Co. have agreed to serve as directors and officers respectively of F Co. at the request of the Project Owners and in consideration of the execution of Agreement #5 by the Project Owners and F Co. ...

X souscrira à XXXXXXXXXX actions de catégorie "XXXXXXXXXX" du capital-actions de NOUCO pour une considération en argent. ...

Y souscrira à XXXXXXXXXX actions de catégorie "XXXXXXXXXX" du capital-actions de NOUCO pour une considération en argent. ...

The Guarantee Agreement will be structured to take into consideration the material obligations of the CT under the above-noted assigned XXXXXXXXXX purchase agreements. ...

That on the redemption by the Holdcos of the Holdco Preference Shares and as a result of the distributions by DC in the course of its winding-up: (a) by virtue of paragraphs 84(3)(a) and 84(3)(b), each of the Holdcos will be deemed to have paid, and DC will be deemed to have received, a taxable dividend at that time equal to the amount, if any, by which the amount paid by each corporation to redeem its Holdco Preference Shares exceeds the PUC of those shares immediately before the redemption; (b) (i) pursuant to paragraph 88(2)(b) and subsection 84(2), but subject to (ii) to (iv) herein, each of the Holdcos will be deemed to have received a dividend (the “winding-up dividend”) on its shares of DC equal to the proportion of the amount by which the aggregate fair market value of the property of DC distributed by DC on the winding-up in consideration for the cancellation of its shares exceeds the PUC thereof that the number of shares of each class held by each of the Holdcos is of the number of shares cancelled; (ii) pursuant to subparagraph 88(2)(b)(i), such portion of the winding-up dividend referred to in (b)(i) as does not exceed DC’s capital dividend account determined immediately before the payment of the winding-up dividend shall be deemed to be the full amount of a separate dividend; (iii) pursuant to subparagraph 88(2)(b)(ii), the portion of the winding-up dividend that is equal to the lesser of: (A) DC’s pre-1972 capital surplus on hand as determined immediately before the payment of the winding-up dividend, and (B) the amount by which the winding-up dividend exceeds the portion, if any, in respect of which DC will elect under subsection 83(2) shall be deemed not to be a dividend; and (iv) pursuant to subparagraph 88(2)(b)(iii), the winding-up dividend, to the extent that it exceeds the portion thereof referred to in (ii) herein that is deemed to be a separate dividend and the portion referred to in (iii) herein that is deemed not to be a dividend, shall be deemed to be a separate dividend that is a taxable dividend; (c) to the extent that the deemed dividends described in (a) and (b) above are taxable dividends, such dividends will be included in the income of the recipient corporation pursuant to paragraph 12(1)(j) and will be deductible in computing the taxable income of the recipient corporation for the year in which the dividends are deemed to have been received pursuant to subsection 112(1) and such deduction will not be denied by any of subsections 112(2.2) to (2.4); (d) the amount of the deemed dividends described in (a) and (b) above will be excluded from the proceeds of disposition of the shares and any loss arising from such disposition of those shares will be reduced by the amount of such dividends pursuant to subsection 112(3); and (e) by virtue of subsections 186(2) and 186(4) of the Act, each of the Holdcos will be connected with DC and DC will be connected with each of the Holdcos. ...

Finco will issue the Preferred Shares to the LENDER for an aggregate cash consideration of approximately $XXXXXXXXXX The entire amount of the subscription proceeds received by Finco from the issuance of its Preferred Shares will be added to its stated capital account maintained by it in respect to its Preferred Shares. ...

La totalité des actions de catégorie «C» de FUSUNICO ont ensuite été rachetées (en XXXXXXXXXX) pour une considération totale de XXXXXXXXXX $. ...

Consideration was also given to E9332223. xxxxxxxxxx xxxxxxxxxx 990354 xxxxxxxxxx Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter dated XXXXXXXXXX, as amended in your numerous letters and facsimiles sent to us in XXXXXXXXXX, wherein you requested advance income tax rulings on behalf of XXXXXXXXXX, in connection with the proposed transactions described below. ...

V corporation's history may be summarized as follows: a) S acquired V by purchase in XXXXXXXXXX for non-share consideration of about U.S. ...

2019 Ruling 2018-0789911R3 F- Post-mortem Pipeline Unedited CRA Tags 20(1)(c), 84(2), 84.1, 245(2) Principales Questions: 1) Whether subsection 84(2) applies to the proposed transactions. 2) Whether section 84.1 will apply to deem the Estate to have received a dividend upon the disposition of shares to the new company. 3) Whether subsection 84.1 will apply to reduce the PUC on the shares of the new company received as consideration for the disposition of the shares. 4) Whether interests on various loans will be deductible pursuant to paragraph 20(1)(c). 5) Whether subsection 245(2) applies to the proposed transactions. ...