Search - consideration

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. ...

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. ...

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. ...

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. ...

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. ...

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. ...

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. ...

As a consequence, this disposition XXXXXXXXXX in a taxable transaction where the proceeds of disposition will be $XXXXXXXXXX. 11.The shares of XXXXXXXXXX, as described in paragraph 10 above, were acquired by XXXXXXXXXX in consideration for common shares of XXXXXXXXXX elected, pursuant to subsection 85(1) of the Act, that the proceeds of disposition of the XXXXXXXXXX properties was XXXXXXXXXX. 12.On XXXXXXXXXX transferred the following assets to its wholly-owned subsidiary, XXXXXXXXXX FMV XXXXXXXXXX 13.As consideration for the assets transferred, XXXXXXXXXX received XXXXXXXXXX common shares of XXXXXXXXXX No election XXXXXXXXXX filed pursuant to subsection 85(1) of the Act with respect to this transfer such that the transfer XXXXXXXXXX fully taxable transaction for the purpose of the Act. 14.The XXXXXXXXXX common shares have a PUC, ACB and fair market value of $XXXXXXXXXX and represent approximately XXXXXXXXXX% of the total assets of XXXXXXXXXX. 15. ... The shares issued will be in consideration for the transfer of shares of XXXXXXXXXX. ... The consideration received for the shares is estimated at $XXXXXXXXXX per share or in total $XXXXXXXXXX This is the value that has been attributed to the XXXXXXXXXX that are held by XXXXXXXXXX. 23.Provided that the XXXXXXXXXX Shareholders approve the Subscription Agreement, there will be concurrent subscription of shares of XXXXXXXXXX The cash obtained from this share subscription will be used for working capital purposes. ...

The Shipcos will pay fair market value consideration for Mgtco’s services. 16. ... Mgtco will pay fair market value consideration for Crewco’s services. 17. ... New Charterco will pay fair market value consideration to the Shipco’s for their services. ...

On XXXXXXXXXX, Canco Predecessor 1 acquired (i) the shares of Canco Sub 1 from Forco in consideration for shares in the capital of Canco, and (ii) the shares of Canco Predecessor 2 from Canco Creditor 1 in consideration for Canco Creditor 1 Note. 4. ... New Partnership will then transfer the note to New Holdco in consideration for a promissory note of New Holdco. ... The transactions described in Paragraph 55(a), (b) and (c) are driven solely by business considerations. ...