Search - consideration
Results 91 - 100 of 1921 for consideration
Ruling
2010 Ruling 2010-0364681R3 - Butterfly Reorganization
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. ...
Ruling
2013 Ruling 2013-0475681R3 - Family holding butterfly transaction
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. ...
Ruling
2006 Ruling 2006-0182211R3 - Public company spin-off
No fractional DC Special Shares will be issued and no additional consideration will be received by a Participant in lieu of a fraction of a DC Special Share. ... As consideration for the Spin-off of the Spin-off Assets to Spinco, Spinco will issue Spinco Special Shares to DC which will have an aggregate fair market value and redemption amount equal to the fair market value, at the time of the Spin-off, of the Spin-off Assets less the amount of the non-share consideration (including any liabilities assumed by Spinco and the Spinco Commitment) paid by Spinco as consideration for the Spin-off Assets, being an amount equal to the Aggregate Spinco Redemption Amount. ... To the extent that the DC Redemption Note and the Spinco Redemption Note are for different amounts, any remaining balance will be settled and extinguished for no additional consideration. ...
Ruling
2025 Ruling 2024-1047551R3 - Multi-wing Split-Up Butterfly
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, TC2 or TC3, as the case may be, or a right to receive such shares. ... For greater certainty, the amount to be added to the stated capital account of each of TC1, TC2 and TC3 for the Class E Preferred Shares issued as partial consideration for the property transferred to it on the DC Transfer will not exceed the maximum amount that could be added to the PUC of such shares without a reduction taking place pursuant to subsection 85(2.1). ... Prior to the Proposed Transactions, DC may dispose of marketable securities, including portfolio investments, for consideration that consists only of money. 43. ...
Ruling
30 November 1997 Ruling E9823353 - AMENDMENT TO BUTTERFLY
No non-share consideration will be paid.” Ruling B will be deleted and will be replaced with the following: “B. Section 84.1 will apply to the sale of the XXXXXXXXXX Distributor Common Shares to Transferee referred to in paragraph 36 as amended above such that the PUC of the Transferee Common Shares issued as the consideration for the sale by Shareholder 4 of the XXXXXXXXXX Distributor Common Shares will be equal to the PUC of the XXXXXXXXXX Distributor Common Shares to Shareholder 4 immediately before that sale. ...
Ruling
30 November 1997 Ruling 9823353 - AMENDMENT TO BUTTERFLY
No non-share consideration will be paid.” Ruling B will be deleted and will be replaced with the following: “B. Section 84.1 will apply to the sale of the XXXXXXXXXX Distributor Common Shares to Transferee referred to in paragraph 36 as amended above such that the PUC of the Transferee Common Shares issued as the consideration for the sale by Shareholder 4 of the XXXXXXXXXX Distributor Common Shares will be equal to the PUC of the XXXXXXXXXX Distributor Common Shares to Shareholder 4 immediately before that sale. ...
Ruling
1999 Ruling 9919223 - SUPPLEMENTARY
Subco is a taxable Canadian corporation and its one common share issued on incorporation for nominal consideration is held by the Employee. ... In paragraph 11, delete the first subparagraph and replace with the following: "XXXXXXXXXX will acquire the one common share of Subco held by the Employee for consideration equal to the fair market value of the one common share at that time. ...
Ruling
1998 Ruling 9815703 - AMENDMENT TO RULING
XXXXXXXXXX will have the right to acquire XXXXXXXXXX interest in the Partnership at its fair market value at the time of winding up the Partnership and as consideration will issue such number of XXXXXXXXXX shares equal to the value of XXXXXXXXXX interest in the Partnership. In the event that XXXXXXXXXX does not exercise its right to acquire XXXXXXXXXX interest in the Partnership, XXXXXXXXXX will have the right to request that XXXXXXXXXX acquire its interest in the Partnership at its fair market value at the time of winding up the Partnership and XXXXXXXXXX will issue as consideration, such number of XXXXXXXXXX shares equal to the value of XXXXXXXXXX interest in the Partnership. ...
Ruling
27 June 1991 Ruling 911243 F - Non-Resident's Income from Canadian Resource Property
We cannot express an opinion as to whether or, if so, when subsection 115(4) applies in the particular case under consideration by you as such an opinion can be formulated only after determination and consideration of all the relevant facts. ...
Ruling
9 January 1991 Ruling 903543 F - Transfer of Property to Corporation
As consideration, Opco receives shares of Bco having an aggregate redemption value equal to the fair market value ("FMV") of the transferred assets. ... Immediately after the transfer, Bco sells the transferred assets to Aco for cash consideration equal to their FMV, which exceeds their ACB. ...