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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. ...

The total consideration received in respect of the disposition of goodwill referred to in paragraph 40 above consisted of both cash and share consideration. Opco 1 received cash consideration of $XXXXXXXXXX and XXXXXXXXXX Class A common shares of BCO with a value of $XXXXXXXXXX. ... Opco 2 received cash consideration of $XXXXXXXXXX and XXXXXXXXXX Class A common shares of BCO with a value of $XXXXXXXXXX. ...

Under XXXXXXXXXX, in general terms, at least XXXXXXXXXX% of the aggregate value of the merger consideration received by shareholders of Targetco will be in the form of Canco common shares. ... No consideration will be issued in exchange for such shares. (h) Under XXXXXXXXXX no fractional shares of Canco will be issued in the XXXXXXXXXX Merger. ... (i) Under XXXXXXXXXX, Mergeco will issue additional common shares (the "Mergeco Shares") at the Effective Time to Canco in consideration for the issuance by Canco of its common shares to the Targetco shareholders. ...

Principal Issues: Whether a right under a shareholder rights plan, obtained by the Target shareholders on a triangular amalgamation in connection with the acquisition of a common share of Parent, will constitute "consideration" other than a share for the purposes of subsection 87(4) Position: No Reasons: The rights will not be received as consideration by the Target shareholders in the context of the facts described in the ruling. ... The Amalgamation Agreement will provide that the shares of Parent and Amalco, as described in this paragraph, will be the sole consideration for the exchange. ... On the amalgamation as described in paragraph 12 above, Parent will receive common shares of Amalco in exchange for its common shares of Subco and in consideration for issuing its own shares to the former shareholders of Target. ...

$XXXXXXXXXX consideration. XXXXXXXXXX. 12. On XXXXXXXXXX, Distributing incorporated Canholdco and subscribed for common shares for $XXXXXXXXXX consideration. 13. ... Parent will incorporate "Newco", a wholly-owned Canadian resident general purpose subsidiary corporation and subscribe for common shares for nominal consideration. Newco will then incorporate a wholly-owned Canadian resident general purpose subsidiary corporation, "Subnewco", and will subscribe for common shares for nominal consideration. 18. ...

Ces actions ont été émises pour une considération globale de XXXXXXXXXX $. 5. ... La Fiducie souscrira à XXXXXXXXXX actions de la catégorie « A » pour une considération globale de XXXXXXXXXX $, soit XXXXXXXXXX $ par action. ... Mme Y souscrira à XXXXXXXXXX actions de la catégorie « A » pour une considération globale de XXXXXXXXXX $, soit XXXXXXXXXX $ par action. ...

The initial Foreign Spinco XXXXXXXXXX was issued to Forco 3 in consideration for $XXXXXXXXXX USD. ... The initial Foreign Spinco Finco XXXXXXXXXX was issued to Foreign Spinco in consideration for $XXXXXXXXXX USD. ... Immediately following the DC ULC Transfer, Canco 1 (which is not a member of the DC ULC Group) will sell to TC ULC GP (which is not a member of the DC ULC Group) its: (a) XXXXXXXXXXCanGP 2 unit in consideration for $XXXXXXXXXX USD; (b) XXXXXXXXXX CanLP 7 unit in consideration for $XXXXXXXXXX USD; (c) XXXXXXXXXX CanLP 11 unit in consideration for $XXXXXXXXXX USD; (d) XXXXXXXXXX CanLP 12 unit in consideration for $XXXXXXXXXX USD; (e) XXXXXXXXXX CanLP 13 unit in consideration for $XXXXXXXXXX USD; (f) XXXXXXXXXX CanLP 14 units in consideration for $XXXXXXXXXX USD; (g) XXXXXXXXXX CanLP 15 unit in consideration for $XXXXXXXXXX USD; (h) XXXXXXXXXX CanLP 18 unit in consideration for $XXXXXXXXXXUSD; and (i) XXXXXXXXXX CanLP 19 unit in consideration for $XXXXXXXXXXUSD. ...

Your suggestion that the Government of Canada hold a lottery to assist with the national deficit has been forwarded to the Department of Finance their consideration. ...

Chisholm and the author we are returning herewith this file to your Division for consideration of the Notice of Objection submitted by the taxpayer. ...

Attached for your consideration, however, are several pages of the draft with comments, queries or suggestions noted thereon. ...