Search - consideration

Results 61 - 70 of 1921 for consideration
Ruling

30 November 1995 Ruling 9633283 - LOSS UTILIZATION SCHEME

In consideration for the transfer, Holdco 1 will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value of the Shares at the time of the transfer. ... As consideration, XXXXXXXXXX will surrender its three notes receivable. 27.Each of Newlossco 1, Newlossco 2 and Newlossco 3 will select the date on which its taxation year will end. ... In consideration for the transfer, Holdco 2 will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value of the Shares at the time of the transfer. ...
Ruling

2010 Ruling 2010-0374141R3 - Stock dividend from CFA & PUC

The issue price of the Consideration Shares generally corresponded to the XXXXXXXXXX. 23. ... The consideration paid by Forco1 to Canco consisted entirely of the Consideration Shares. 25. ... In the year XXXXXXXXXX, Forco3 was transferred to Forco1 in exchange for XXXXXXXXXX Consideration Shares with an issue price of approximately US$XXXXXXXXXX; c. ...
Ruling

2002 Ruling 2002-0133083 - In-House Loss Utilization

As consideration, Opco will surrender the Newlossco1 Note and Newlossco2 Note. ... As consideration, Opco will surrender the Newlossco3 Note and Newlossco4 Note. ... As consideration, Opco will surrender the Newlossco5 Note and Newlossco6 Note. ...
Ruling

2007 Ruling 2007-0256351R3 - XXXXXXXXXX Corporate Reorganization

As a result, the second unenumerated paragraph of paragraph 32 of the Ruling is amended to read as follows: The addition to the stated capital under the BCA of the common shares issued by S Co as consideration for the shares transferred to it, as described above, will not exceed the aggregate paid-up capital of such transferred shares. The second unenumerated paragraph of paragraph 33 is amended to read as follows: The addition to the stated capital under the BCA to the common shares issued by F Co as consideration for the shares transferred to it, as described above, will not exceed the aggregate paid-up capital of such transferred shares. ...
Ruling

14 February 1990 Ruling YS9001601 F - Remission of Income Tax

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of your case. ...
Ruling

31 January 1990 Ruling 90016011 F - Request for Remission of Income Tax and Interest

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure a fair and uniform application of established criteria. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of your case. ...
Ruling

15 May 1990 Ruling 90065001 F - Time Limit for Assessment

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office.  ... I wish to assure you that 19(1) will receive the utmost consideration possible in her case. ...
Ruling

27 April 1990 Ruling 90M04003 F - Remission of Tax

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office.  ... I wish to assure you that he will receive the utmost consideration possible in the resolution of his case. ...
Ruling

17 October 2012 Ruling 2010-0376681R3 - Internal reorganization - 55(3)(a)

The shareholders of Opco will not receive any non-share consideration on the merger. ... As consideration, Amalco will issue a demand, non-interest bearing, promissory note (“Note10”) with a principal amount equal to the FMV of the shares redeemed. 59. ... As consideration, Amalco will issue a demand, non-interest bearing, promissory note (“Note11”) with a principal amount equal to the FMV of the shares redeemed. 60. ...
Ruling

2004 Ruling 2004-0081531R3 - XXXXXXXXXX - Internal Restructuring

Parent will transfer to Transferee that number of issued and outstanding common shares of Distributing which have an aggregate fair market value equal to the fair market value of the Newco Common Shares, in consideration for the issue by Transferee to Parent of additional common shares. ... Distributing will transfer to Transferee the common shares of Cansub1 in consideration for cash in an amount equal to XXXXXXXXXX and the issue by Transferee to Distributing of a number of spin off preferred shares having an aggregate fair market value equal to the aggregate fair market value of the common shares of Cansub1 less the amount of cash consideration paid by it to Distributing. ... As consideration for the transfer of the XXXXXXXXXX Shares by Distributing to Transferee, Transferee will issue to Distributing a number of spin off preferred shares having an aggregate fair market value equal to the fair market value of the XXXXXXXXXX Shares so transferred to it. ...

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