Search - consideration

You have advised that the Ruling did not properly identify the class of shares that are to be issued by TC1 and TC2 in consideration for the acquisition of the shares of DC. ... Consideration will consist of a debt issued by TC2 of an amount equal to the lesser of the aggregate hard ACB in respect of the Class A and Class E shares, and the aggregate of the agreed amounts in respect of the Class A and E shares, less $XXXXXXXXXX, and a number of Class E shares in the capital stock of TC2 with a FMV and redemption amount equal to the difference between the FMV of the Class A and Class E shares less the FMV of the debt issued. ... Consideration will consist of a debt issued by TC1 of an amount equal to the lesser of the aggregate hard ACB in respect of the Class A and Class E shares and the aggregate of the agreed amounts in respect of the Class A and E shares, less $XXXXXXXXXX, and a number of Class F shares in the capital stock of TC1 with a FMV and redemption amount equal to the difference between the FMV of the Class A and Class E shares less the FMV of the debt issued. ...

The first opinion you request is that Canco's proceeds of disposition ("POD") in respect of any NewCanco Common Shares it must deliver to an existing Canco warrant holder under the NewCanco warrant agreement as described in paragraph 21 of the Ruling, shall not exceed a reasonable allocation of the sum of: (a) the consideration that Canco received from the particular Canco warrant holder at the time such Canco warrant was issued to such Canco warrant holder by Canco (i.e., the "issue price"); plus (b) the additional consideration that such Canco warrant holder may be required to pay to Canco at the time such Canco warrants are exercised (the "exercise price"). ... In consideration of this request you advise that while certain of the proposed transactions described in the Ruling may have already commenced or been completed the proposed transactions described in paragraph 21 of the Ruling have not yet occurred. ...

., consideration would be given to substance over form).  The limited information contained in your correspondence would lead us to conclude that the expense represented membership dues. ... A third consideration is that, to be deductible, the maintenance costs would have to be incurred by the taxpayer in the course of carrying on the business of operating the club or recreational facility for hire or reward, for the purposes of paragraph 18(1)(l)(i). ... Depending on the facts of a particular situation, there may also be other considerations.  ...

As stated in Interpretation Bulletin IT-339R, a PHSP must be in the nature of insurance and must contain the following elements: (i)     an undertaking of one person, (ii)     to indemnify another person, (iii)      for an agreed consideration, (iv)     from a loss or liability in respect of an event, (v)     the happening of which is uncertain. ... The agreed consideration may take the form of cash premiums computed on an actuarial basis. ... In these cases, the consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or contract of service. ...

The Newco Preferred Shares will have the following attributes: (a) Newco Class A Preferred Shares (i) non-voting; (ii) non-participating; (iii) redeemable at the option of the issuer and retractable at the option of the holder for a redemption price equal to the fair market value of the consideration for which the shares are issued. ... (b) Newco Class B Preferred Shares (i) non-voting; (ii) non-participating; (iii) redeemable at the option of the issuer and retractable at the option of the holder for a redemption price equal to the fair market value of the consideration for which the shares are issued. ... (c) Newco Class C Preferred Shares (i) voting; (ii) non-participating; (iii) redeemable at the option of the issuer and retractable at the option of the holder for a redemption price equal to the fair market value of the consideration for which the shares are issued. ...

The Plaintiff has reached a settlement with the Defendants with respect to the claims, for periodic payments (the "Structure Payments") and certain non-structure consideration subject to receipt of a favourable income tax ruling with respect to the Structure Payments. 6. The terms of the Settlement Agreement provide, among other consideration, for the payment to the Plaintiff of lifetime monthly payments of $XXXXXXXXXX, without indexation, commencing on XXXXXXXXXX (which monthly payments are guaranteed to be made through XXXXXXXXXX, regardless of whether the Plaintiff is alive), plus lump sum payments of $XXXXXXXXXX due on XXXXXXXXXX, respectively. 7. ... In consideration of the Insurer making the Structured Payments (and the other defendants either directly or through their insurers, providing certain non-structure consideration called for the Settlement Agreement and Release) the Plaintiff has agreed to settle her claims against the Defendants. 8. ...

(ci-après, "Considération FNLR1") d'un montant qui correspondra à 50% des Frais nets de location reportés immédiatement avant le moment de l'attribution. ... Paiement d'une partie du Billet2 payable par NOUCO à OPCO NOUCO prendra aussi en charge 50 % des dettes restantes de OPCO immédiatement avant la troisième série de transferts, autres que les dettes comprises dans la Considération FNLR1, la Considération DPC1-NOUCO, la Considération FNLR2 et la Considération DPC1-GESTCO1. ... Paiement d'une partie du Billet2 payable par GESTCO1 à OPCO GESTCO1 prendra en charge 50 % des dettes restantes de OPCO immédiatement avant la troisième série de transferts, autres que les dettes comprises dans la Considération FNLR1, la Considération DPC1-NOUCO, la Considération FNLR2 et la Considération DPC1-GESTCO1. ...

As sole consideration for the transfer, Spouse 1 will receive XXXXXXXXXX Class I preferred shares (non-voting) of Opco 2 redeemable/retractable at $XXXXXXXXXX/share and having an aggregate FMV equal to the aggregate FMV of the Opco 1 shares so transferred. ... As sole consideration for the transfer, Opco 1 will receive XXXXXXXXXX Class I preferred shares (non-voting) in Holdco 1 redeemable/retractable at $XXXXXXXXXX/share and having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX so transferred. ... Opco 2 will assign the receivable from Promissory Note 1 which was issued to Opco 2 by Opco 1 in Paragraph 27 to Holdco 1 in consideration for the partial set-off of Promissory Note 4 (owed by Opco 2 to Holdco 1). 33. ...

As consideration therefor, Sub-Transferee A will issue to DC1 the Sub-Transferee A Note 1. ... As consideration therefor, Transferee B will issue to DC1 the Transferee B Note 1. ... As consideration therefore, Transferee B will issue to DC2 the Transferee B Note 2. ...

The dispositions of these partnership interests were made for cash consideration only. 21. ... DC will dispose of marketable securities for consideration that consists only of cash. 33. ... The consideration received by Sibling1 will be additional common shares of the capital stock of TC1. ...