Search - consideration
Results 211 - 220 of 1913 for consideration
Ruling
2002 Ruling 2002-0168463 - REIT with seconded employees
Neither are unit trusts and no one acquired an interest in either for consideration, taking 108(7) into consideration. 8. ... The consideration payable for the interest will be satisfied by the assumption of the mortgage in the approximate amount of $XXXXXXXXXX and the balance of $XXXXXXXXXX will be paid in cash or a combination of cash, Units or the transfer of a convertible debenture. ... The Trust, as partial consideration for the acquisition of these particular Co-Owned Properties, will assume 100% of such indebtedness, which amount does not exceed the fair market value of the undivided interest being acquired by the Trust. ...
Ruling
1998 Ruling 9830573 - BUTTERFLY REORGANIZATION
Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX, for cash consideration of $XXXXXXXXXX. Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX for cash, consideration of $XXXXXXXXXX. Upon its organization, XXXXXXXXXX issued one (1) class A common share to XXXXXXXXXX, representing the sole issued and outstanding share in the capital of XXXXXXXXXX, for cash consideration of $XXXXXXXXXX. 10. ...
Ruling
1998 Ruling 9817073 - DISCOUNT BONDS
The Offer was amended on XXXXXXXXXX so that the consideration payable for each BCO share tendered to the Offer is equal to XXXXXXXXXX. The Offer also provides that the maximum number of ACO Non-Voting Shares issuable pursuant to the offer is limited to XXXXXXXXXX% of the total consideration payable and the maximum amount of cash payable by ACO pursuant to the Offer is limited to XXXXXXXXXX% of the total consideration payable. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Ruling
2018 Ruling 2018-0778961R3 - Partial transfer to new funds
Also at that time, the Series D and/or Series O Units held by Exchanging Unitholders in the Participating XXXXXXXXXX Public Fund will be cancelled for no consideration. ... As noted, it is not intended that this holding of units in XXXXXXXXXX will be retained; rather, as described below, New XXXXXXXXXX will dispose of this investment following completion of the foregoing proposed transactions. 1.3.9 Following the completion of the foregoing steps described above, on or shortly after the Effective Day, New XXXXXXXXXX and investors in the XXXXXXXXXX Group will dispose of their Units in XXXXXXXXXX in exchange for cash or in kind consideration. ... The Transferor will receive Units of the Transferee as the sole consideration for such property. ...
Ruling
2010 Ruling 2010-0373801R3 - Conversion from a BV to a DC
As sole consideration for the transfer, DC will increase Holdco's membership interest in DC by an amount that will be equal to the fair market value of the FAcos' shares transferred by Holdco to DC. ... As sole consideration for the transfer, DC will increase Newco's membership interest in DC by an amount that will be equal to the fair market value of the FAcos' shares transferred by Newco to DC. ... The cancellation of the shares in the capital of BV on the Conversion in exchange for the issuance of the membership interests in DC will occur on a tax-deferred basis for the purposes of the Act, pursuant to subsection 86(1), such that: (i) the cost to Holdco of the shares of DC receivable as consideration for the cancellation of the BV shares will be deemed to be equal to Holdco's adjusted cost base of its shares of BV immediately before the Conversion; (ii) Holdco shall be deemed to have disposed of the BV shares for proceeds of disposition equal to the cost of the DC shares receivable by Holdco referred to in C(i) above; (iii) the cost to Newco of the shares of DC receivable as consideration for the cancellation of the BV shares will be deemed to be equal to Newco's adjusted cost base of its shares of BV immediately before the Conversion; and (iv) Newco shall be deemed to have disposed of the BV shares for proceeds of disposition equal to the cost of the DC shares receivable by Newco referred to in C(iii) above. ...
Ruling
2005 Ruling 2005-0123631R3 - Thin Capitalization Rules
On XXXXXXXXXX, CanCo transferred its interest in ForeignCo to Can-FHoldCo and received, as consideration, additional shares of Can-FHoldCo. ... On XXXXXXXXXX, Foreign Parent transferred its XXXXXXXXXX% interest in CanCo to Newco and received, as consideration, additional shares of Newco. 19. ... As consideration, CLP will pay LuxFinCo an amount of C$XXXXXXXXXX cash and will issue notes payable to LuxFinCo for the balance (the "CLP Notes"). ...
Ruling
2015 Ruling 2015-0565151R3 - Supplemental Ruling
As sole consideration for such transfer, XXXXXXXXXX. The transfer will occur on a tax-deferred basis pursuant to subsection 85(1). ... As consideration for such contribution, XXXXXXXXXX will issue XXXXXXXXXX, having an aggregate FMV equal to $XXXXXXXXXX. ... As consideration for such transfer, XXXXXXXXXX will pay XXXXXXXXXX to XXXXXXXXXX. ...
Ruling
2010 Ruling 2009-0351351R3 - Post Butterfly Transactions
All of the shares of TC2 held by DC were redeemed in consideration of the issue of a promissory note by TC2 to DC. ... No amount was paid in consideration of the non-compete. Proposed Transactions 19. ... No other consideration will be received by TC1 on the share exchange. ...
Ruling
2008 Ruling 2008-0264671R3 - Entity Classification
Parent granted the Shareholder a XXXXXXXXXX % "net operating profit interest" and issued additional common shares to the Shareholder as the sole consideration for the shares of Holdco acquired by it. ... Parent will receive additional membership interests in DC as the sole consideration for the shares of Subco transferred to DC. ... Parent will receive additional membership interests in DC as the sole consideration for the shares of Holdco transferred to DC. ...
Ruling
30 November 1995 Ruling 9626823 - REORG SHAREHOLDER TO PARTNER
In consideration for the disposition of the Partnership Units, XXXXXXXXXX will issue two non-interest-bearing promissory notes with an aggregate principal amount equal to the fair market value of the XXXXXXXXXX units at the time of the transfer. ... The second promissory note (the "Non-Tax Note") will be issued for a principal amount equal to the amount of consideration less the amount of the Tax Note. ... F.Provided that, in each case, the aggregate fair market value of the transferred property is not less than the aggregate fair market value of consideration given in exchange, subsection 15(1) will not apply to the transfers of property described in paragraphs 11, 13, 14 and 16 above. ...