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Mancino, Director, Source Deductions Division (tel. 954-1284) for consideration and reply. ...

12 January 1990 Ruling 90M01691 F- Technical Bill Unedited CRA Tags n/a   January 12, 1990   SECRET      of 10 MEMORANDUM FOR POLICY COMMITTEE MEMBERS SUBJECT:  TECHNICAL BILL Attached, for consideration at a meeting(s) to be arranged, is a copy of additional draft legislation and technical noted received from Finance to date for inclusion in the upcoming Technical Bill. ...

As a result of the winding up of the partnership, the consideration received by the partnership from DC on the transfer of the XXXXXXXXXX assets was distributed equally between Mr. ... As consideration for the transfer, Mr. A will receive common shares in the capital of TC1 with an aggregate FMV equal to the aggregate FMV, at the time of the transfer, of the DC Shares transferred to TC1. ... As consideration for the transfer, Mr. B will receive common shares in the capital of TC2 with an aggregate FMV equal to the aggregate FMV, at the time of the transfer, of the DC Shares transferred to TC2. ...

DC will subscribe for XXXXXXXXXX common shares of DC Subco for consideration in the amount of $XXXXXXXXXX per share. ... DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee A for fair market value consideration. ... DC2 will purchase for cancellation all of common shares and Class C Shares, if any, of its capital stock owned by Transferee J for fair market value consideration. ...

As the sole consideration therefor, Transferee 2 will issue to Individual 2 a number of Class A common shares of Transferee 2 having an aggregate FMV equal to the aggregate FMV at that time of Individual 2's DC Shares. ... For the purposes of the BCA, $XXXXXXXXXX will be added to the stated capital for all of the Transferee 1 Class C Preferred Shares that are issued as consideration for Property1 as described in Paragraph 28 and $XXXXXXXXXX will be added to the stated capital for all of the Transferee 2 Class C Preferred Shares that are issued as consideration for Property2 as described in Paragraph 28. 32. ... As consideration therefor, DC will issue to Transferee 1 a demand non-interest bearing promissory note having a principal amount and FMV equal to the aggregate FMV of the Class A Shares so purchased for cancellation (the "DC Redemption Note 1"). ...

As the sole consideration for the receipt of Individual 2's DC Shares, Transferee 2 will issue to Individual 2 Class A common shares of the capital stock of Transferee 2 having an aggregate FMV equal to the FMV at that time of Individual 2's DC Shares. ... Similarly, the amount to be added to the stated capital of the Transferee 1 Class B common shares, that are issued as consideration for Sibling 2's DC Shares as described in Paragraph 23(b), will be an amount that is equal to the aggregate PUC of Sibling 2's DC Shares and the amount to be added to the stated capital of the Transferee 2 Class A common shares, that are issued as consideration for Individual 2's DC Shares as described in Paragraph 23(c), will be an amount that is equal to the aggregate PUC of Individual 2's DC Shares. 27. ... For the purposes of the BCA, $XXXXXXXXXX will be added to the stated capital for all of the Transferee 1 Class C Preferred Shares that are issued as consideration for Property3 as described in Paragraph 28 and $XXXXXXXXXX will be added to the stated capital for all of the Transferee 2 Class C Preferred Shares that are issued as consideration for Property2 and Property4 as described in Paragraph 28. 32. ...

“TC1 Redemption Note” means the non-interest bearing demand promissory note issued by TC1 to DC as consideration for the redemption by TC1 of the TC1 Butterfly Share held by DC. ... “TC2 Redemption Note” means the non-interest bearing demand promissory note issued by TC2 to DC as consideration for the redemption by TC2 of the TC2 Butterfly Share held by DC. ... As consideration for the redemption, TC1 will issue the TC1 Redemption Note, TC2 will issue the TC2 Redemption Note and TC3 will issue the TC3 Redemption Note. ...

As consideration for the shares, CanSub1 will issue the CanSub1 Note. ... As consideration for the shares, CanSub2 will issue the CanSub2 Note. ... As consideration for such interests, ForSub2 will pay an amount of cash equal to the aggregate FMV of such interests at the time of the transfer. 29. ...

As sole consideration for such transfer, Newco 2 will issue to Child 2 an equal number of redeemable, retractable Class XXXXXXXXXX preferred shares having a fair market value and aggregate redemption amount equal to the fair market value of the Class XXXXXXXXXX preferred shares of Amalco transferred therefor. ... As sole consideration for such transfer, Newco 3 will issue to Child 3 an equal number of redeemable, retractable Class XXXXXXXXXX preferred shares having a fair market value and aggregate redemption amount equal to the fair market value of the Class XXXXXXXXXX preferred shares of Amalco transferred therefor. ... In consideration for such transfers, each of Newco 1, Newco 2 and Newco 3 will issue XXXXXXXXXX Class XXXXXXXXXX preferred shares and assume the Newco 1 Proportion, the Newco 2 Proportion or the Newco 3 Proportion, as the case may be, of the liabilities of Amalco. ...

Sibling 1 Trust will transfer its XXXXXXXXXX DC Common Shares to TC1 in exchange for TC1 issuing XXXXXXXXXX TC1 Common Shares as sole consideration therefor having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX DC Common Shares transferred. 28. ... The agreed amount in respect of each eligible property so transferred will not be greater than the FMV of such property nor will it be less than the FMV, at the time of disposition, of the consideration therefor other than shares of the capital stock of TC1 or TC2, as the case may be, or a right to receive such shares. ... As consideration therefore, TC1 and TC2, as the case may be, will issue to DC the TC1 Redemption Note in respect of TC1’s share redemption and the TC2 Redemption Note in respect of TC2’s share redemption, each having a principal amount and FMV equal to the redemption amount of such TC’s Butterfly Shares. ...