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To the extent that the transfers result in a Holdco owing fractional interests in the marketable securities, the Holdcos may sell the fractional interests among themselves for fair market value consideration, however any such sales will be made within the parameters of paragraph 55(3.1)(c). As consideration for the transferred properties referred to above, each Holdco will: (a) assume one-third of the current accounts payable of XXXXXXXXXX, and one-third of the shareholder loans of XXXXXXXXXX; and (b) issue to XXXXXXXXXX Class XXXXXXXXXX Preference Shares of its capital stock having an aggregate redemption amount and fair market value equal to the amount by which the fair market value of the transferred properties received by it as a result of the transfers described herein exceeds the fair market value of the liabilities of XXXXXXXXXX assumed by it. ...

To the best of XXXXXXXXXX knowledge, none of the matters referred to in this request for advance income tax rulings is currently under objection or consideration by a District Taxation Office or Taxation Centre in connection with a return already filed. ... These rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R2 dated September 28, 1990 and are binding on Revenue Canada, Taxation provided that the proposed transactions described herein are completed by XXXXXXXXXX Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

Holdco will transfer all of the shares of USCos which it presently owns to USHoldco in exchange for shares of USHoldco and no other consideration, pursuant to subsection 85.1(3) of the Act. 4. Each of Aco, Bco, and Cco will transfer the shares of the LLCs currently owned by Aco, Bco and Cco, respectively, to USHoldco in exchange for shares of USHoldco and no other consideration, pursuant to subsection 85.1(3) of the Act. ...

To the best of your knowledge and that of the XXXXXXXXXX none of the issues referred to herein are currently under objection or consideration by a Tax Services Office or Taxation Centre in connection with a return already filed. ... Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...

However, the concept of local transportation may be addressed in provincial legislation regulating remunerated truck transportation services within a province and it is our opinion chat where a provincial truck transportation act establishes the boundaries surrounding an urban or metropolitan area in that province within which local transportation takes place, that boundary would be an important consideration in the determination of what constitutes "hauling freight locally". ... Taking into consideration these definitions, in our opinion, for the province of Ontario travel within an urban municipality which can be loosely defined as an incorporated city or town should be considered commercial travel.  ...

Holdco 3 will subscribe for one common share in the capital of Newco 3 for nominal consideration. ... As sole consideration for these transfers, Newco 2 will issue Class A Shares to Mr. ... As sole consideration for these transfers, Holdco 1 will issue Class A Shares to Mr. ...

DC2 will dispose of the automobile to New Holdco4 at its FMV, for all cash consideration (approximately $XXXXXXXXXX). 103. ... Upon incorporation, Subco1 will issue XXXXXXXXXX Subco1 Common Share to Holdco1 for $XXXXXXXXXX cash consideration. ... Upon incorporation, Subco2 will issue one Subco2 Common Share to Holdco2 for $XXXXXXXXXX cash consideration. ...

(l) Foreign Sub 2 sold XXXXXXXXXX to Forco 1 in consideration for cash proceeds equal to the FMV of XXXXXXXXXX. ... (ii) Canco 4 sold XXXXXXXXXX in a taxable sale to Canco 7 for FMV consideration. (iii) Canco 4 sold the XXXXXXXXXX) in a taxable sale to Forco 12 for FMV consideration. ...

Debtor will receive from Debtor's Sub #3, as sole consideration for the transfer of its depreciable assets, shares of Debtor's Sub #3. ... The XXXXXXXXXX Unsecured Creditors will receive this consideration from Debtor. Debtor will issue XXXXXXXXXX Common Shares to New Debtor in consideration for New Debtor's delivery of the consideration to Debtor, which will then deliver this consideration directly to the XXXXXXXXXX Unsecured Creditors. ...

Options to each of X Co. and Newco in consideration for the issuance to the particular holder of New X Co. ... Redemption Amounts and will issue to Y Co. in consideration therefore the X Co. ... Redemption Amounts and will issue to X Co. in consideration therefore the Y Co. ...