Search - consideration

Results 21 - 30 of 1921 for consideration
Ruling

2009 Ruling 2009-0312081R3 - Donation of Exchangeable Shares

With the exception of CCO, the Taxpayers acquired their Exchangeable Shares on XXXXXXXXXX, in consideration of their transfer to ACO of their Units. ... DCO acquired these Exchangeable Shares on XXXXXXXXXX, in consideration of its transfer to ACO of its Units. ... The relevant Taxpayer will receive, as consideration for the Exchange, the Exchange Consideration, which will consist solely of BCO Shares. ...
Ruling

2002 Ruling 2002-0161323 - Split up Butterfly

The two promissory notes issued by TC1 will be referred to as the "TC1 Consideration Notes" and the two promissory notes issued by Subco2 will be referred to as the "Subco2 Consideration Notes". ... In connection with the winding-up of DC, DC will distribute the TC1 Consideration Notes and the TC1 Redemption Note to TC1 and the Subco2 Consideration Notes and the Subco2 Redemption Note to TC2. As a result of the assignment and distribution of the TC1 Consideration Notes and the TC1 Redemption Note to TC1, the obligations under each such promissory note will be cancelled. ...
Ruling

2006 Ruling 2005-0161711R3 - Participating Interest

The Disposition occurred on XXXXXXXXXX and the consideration received by XCo XXXXXXXXXX. The proceeds of disposition to XCo for purposes of the Act was equal the FMV of the consideration received. ... The total principal amount of the ACo Debt was approximately $XXXXXXXXXX; (i) AcquisitionCo acquired the XXXXXXXXXX Consideration from XAmalco; and (j) AcquisitionCo transferred the XXXXXXXXXX Consideration to each holder of XXXXXXXXXX Notes in exchange for and in cancellation of such notes. 15. ...
Ruling

2000 Ruling 2000-0049053 - 55(3)(a) - significant increase in interest?

(c) On XXXXXXXXXX sold its XXXXXXXXXX portfolio to an arm's-length third party in consideration for cash equal to the fair market value of the portfolio. ... (d) XXXXXXXXXX sold XXXXXXXXXX operations to arm's-length third parties in consideration for cash equal to the fair market value of such assets. ... (f) XXXXXXXXXX will sell all of the shares of each of XXXXXXXXXX to XXXXXXXXXX in consideration for cash equal to the fair market value of such shares. ...
Ruling

2002 Ruling 2002-0168603 - XXXXXXXXXX

On or before XXXXXXXXXX, and immediately before the transactions described below, US Subco will purchase the following assets from various members of Group A at their FMV and issue the following FMV consideration: i) shares of USco 7 from USco 3 for sole consideration consisting of US$XXXXXXXXXX in cash; ii) the Group A-1 Assets from USco 13 for sole consideration consisting of XXXXXXXXXX newly issued common shares of US Subco with a FMV of US$XXXXXXXXXX; and iii) the Group A-2 Assets from USco 18 for consideration consisting of XXXXXXXXXX newly issued common shares of US Subco with a FMV of US$XXXXXXXXXX, US$XXXXXXXXXX in cash and US$XXXXXXXXXX newly issued non-voting preferred shares of US Subco with a FMV of US$XXXXXXXXXX As a result of the above, the aggregate purchase price for the above assets acquired by US Subco will be equal to their aggregate FMV of US$XXXXXXXXXX and the aggregate FMV consideration to be paid by US Subco in respect of these assets will consist of US$XXXXXXXXXX of common shares of US Subco, US$XXXXXXXXXX of non-voting preferred shares of US Subco and cash of US$XXXXXXXXXX. 13. Newco US will then purchase all the issued and outstanding common shares of US Subco for their FMV in exchange for cash and/or common shares of Newco US that have a FMV equal to the US Subco shares so acquired by Newco US as follows: i) USco 13 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of XXXXXXXXXX newly issued common shares of Newco US with a FMV of US$XXXXXXXXXX; ii) USco 18 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of XXXXXXXXXX newly issued common shares of Newco US with a FMV of US$XXXXXXXXXX; and iii) USco 4 will transfer its XXXXXXXXXX common shares of US Subco to Newco US for sole consideration consisting of US$XXXXXXXXXX in cash. ... As sole consideration therefor, Pubco will issue notes payable with an aggregate principal amount and FMV of US$XXXXXXXXXX (the "Pubco Notes"). ...
Ruling

2011 Ruling 2010-0379741R3 - Reorganization of a group of related corporations

The CANCO4 Shares are all owned by CANCO1, having been purchased from an arm's length party on XXXXXXXXXX for a cash consideration of $XXXXXXXXXX. ... Each asset which comprises the division will be transferred in exchange for consideration equal to its fair market value. b. ... A will transfer the CANCO1 Subsidiary shares to SUBHOLDCO3 for consideration consisting of preference shares of the capital stock of SUBHOLDCO3 with a fair market value and a redemption amount equal to the fair market value of the CANCO1 Subsidiary shares. a. ...
Ruling

2001 Ruling 2000-0049963 - Reorganization

For greater certainty, no non-share consideration will be paid by A Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by B Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by C Holdco in respect of the transfer of the shares so acquired by it. ...
Ruling

2009 Ruling 2007-0261171R3 - Post butterfly transaction

On incorporation, Real Co subscribed for at least one Common Share of each of the Real-Subcos for nominal consideration. ... On incorporation, TC3 subscribed for at least one Common Share of each of the TC3-Subcos for nominal consideration. ... Real Co will transfer to TC3 all of its Common Shares of each of the Real-Subcos in consideration for Common Shares of TC3. 23. ...
Ruling

2007 Ruling 2007-0231331R3 - Amalgamation and bump

Management received the Rollover Consideration and the other Holders received cash. ... Parent subscribed for common shares of Shareholder 5 in consideration for $XXXXXXXXXX. 9(L). ... Bidco subscribed for common shares of Buyerco in consideration for approximately $XXXXXXXXXX. 10. ...
Ruling

2005 Ruling 2005-0132891R3 - In-house loss consolidation

As sole consideration for these transfers, Wind-upco1 will issue to Parentco common shares of its capital stock. 22. ... As consideration, Parentco will surrender the Newlossco1 Note, Newlossco2 Note and Newlossco3 Note. ... As consideration, Parentco will surrender the Newlossco4 Note and Newlossco5 Note. ...

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