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Ruling

2014 Ruling 2013-0498651R3 - Single-Wing Split-up Butterfly

The bulk of DC's farm machinery and equipment was sold at auction in XXXXXXXXXX for cash consideration of $XXXXXXXXXX. ... Therefore, certain farm machinery and equipment was retained by DC and sold annually to the Partnership for cash consideration. ... As consideration therefor, TC will issue to DC Promissory Note1. DC will accept Promissory Note1 as full payment for the aggregate redemption amount of the TC Preferred Shares so redeemed. 27. ...
Ruling

2010 Ruling 2009-0306341R3 - Trusts as Shareholders on a Butterfly

Having regard to paragraph 84.1(1)(a), no amount will be added by either SiblingCo to the stated capital account maintained for any particular class of shares of its capital stock issued to a Trust in consideration of the transfer by the Trust of its DC shares. 14. In the event that shares of a SiblingCo are issued to a particular Trust in consideration for the transfer by it of DC shares in accordance with Subparagraph 13(b) above, the particular Trust will jointly elect with that SiblingCo, in prescribed form and within the time referred to in subsection 85(6), to have the rules in subsection 85(1) apply to such transfer. ... Where a marketable security to be transferred by DC to a SiblingCo has a FMV that is less than its ACB, the particular SiblingCo will not assume liabilities of DC in an amount greater than the FMV of the particular security as consideration for such marketable security and, for greater certainty, no election under subsection 85(1) will be made in respect of the transfer of such security. 21. ...
Ruling

2010 Ruling 2009-0325191R3 - Standard Split-up Butterfly

Grandmother will transfer her XXXXXXXXXX Class "C" and XXXXXXXXXX Class "D" Common Shares in the capital of DC to TC and in consideration therefore, TC will issue a number of Class "D" Preferred Shares having an aggregate redemption amount and FMV equal to the FMV of the Common Shares of DC transferred to TC. ... As consideration therefore, TC will issue a non-interest bearing demand promissory note (the "TC Note") having a principal amount and FMV equal to the aggregate redemption amount and FMV of the Class "E" Preferred Shares in the capital of TC redeemed. ... Nothing in this letter should be construed as confirmation, express or implied, that, for the purpose of any of the rulings given above, any adjustment to the FMV of the properties transferred or the redemption amount of the shares issued as consideration, whether pursuant to a price adjustment clause or otherwise, will be effective retroactively to the time of the transfer and issuance of shares. ...
Ruling

2007 Ruling 2006-0182221R3 - Reorganization of a mutual fund trust - s. 132.2

The Fund will subscribe for that number of XXXXXXXXXX Special Units as is equal to the number of its issued and outstanding Units in consideration for a cash payment estimated at $XXXXXXXXXX per XXXXXXXXXX Special Units. ... No consideration other than XXXXXXXXXX Special Units will be received by the Unitholders on the redemption of the Class A Shares and no consideration other than XXXXXXXXXX Ordinary units will be received by XXXXXXXXXX on the redemption of the Class B Shares. 35. ... No consideration other than Fund Special Units will be received by the Unitholders on the redemption of the XXXXXXXXXX Special Units and no consideration other than Units will be received by the Fund on the redemption of the XXXXXXXXXX Ordinary Units. 39. ...
Ruling

2007 Ruling 2007-0245711R3 - full split-up butterfly

In XXXXXXXXXX, DC's Aco shares were redeemed by Aco and a loan that DC owed to Aco was set-off by Aco as consideration for such redemption. ... As consideration therefor, Newco 1 will issue to Sibling 1 a number of Newco Class A Special Shares having an aggregate redemption amount and aggregate FMV equal to the aggregate FMV of the DC shares so transferred by Sibling 1 to Newco 1. ... As consideration therefor, Newco 2 will issue to Sibling 2 a number of Newco Class A Special Shares having an aggregate redemption amount and aggregate FMV equal to the aggregate FMV of the DC shares so transferred by Sibling 2 to Newco 2. ...
Ruling

2006 Ruling 2006-0182271R3 - Reorganization of a mutual fund trust - s. 132.2

Under the Fund DOT, the Fund is authorized to issue an unlimited number of Fund Rights in connection with or in relation to an issuance of securities that carry a right to convert or exchange into Fund Units for no additional consideration. ... The Fund will subscribe for one XXXXXXXXXX Common Share, the consideration for which will be $XXXXXXXXXX cash. 31. ... The Fund will subscribe for one MFC Common Share, the consideration for which will be a cash payment of $XXXXXXXXXX. 35. ...
Ruling

30 November 1996 Ruling 9701663 - SPLIT UP OF A CORPORATION

No other consideration will be received by Parentco in respect of the Share Reorganization. ... Parentco will sell all of the Target Reorganization Shares held by it to Holdco1 and will receive, as sole consideration therefor, XXXXXXXXXX common shares of Holdco1. ... Coincident with the sale described in paragraph 18 above, Parentco will sell all of the Opco Reorganization Shares held by it to Holdco2 and will receive, as sole consideration therefor, XXXXXXXXXX common shares of Holdco2. ...
Ruling

2003 Ruling 2003-0031823 - Transfer of a Business by a Shareholder

XCO will transfer to Subco XXXXXXXXXX at FMV and as consideration therefor, Subco will issue to XCO an additional XXXXXXXXXX common shares. 23. ... The existing employee stock options will be cancelled for no consideration and Newco will issue to its employees options to acquire common shares of Newco. ... XCO will transfer its interest in PartnershipA to Aco and as consideration therefor, Aco will issue to XCO Aco Class A Common Shares and Aco Class B Common Shares. ...
Miscellaneous severed letter

7 July 2007 Income Tax Severed Letter 2007-0237481R3 - Purchase of target and bump

CanSub sold its XXXXXXXXXX% interest in Opco to InvestmentCo for nominal cash consideration. ... Bidco will subscribe for shares of the capital stock of Newco for a nominal cash consideration. 42. Bidco will transfer all of the Target Shares to Newco for FMV consideration. ...
TCC

Lyrtech RD Inc. v. The Queen, 2013 DTC 1147 [at at 820], 2013 TCC 12, aff'd 2014 FCA 267

As consideration, the appellant issued a demand promissory note to Lyrtech in the amount of $1,016,437.   32.       ... As consideration, the appellant obtained a share in future income. The appellant was entitled to 10% of the income from sales of the products resulting from the R&D work and 25% of the income from licences granted with respect to those products.   37.       ...   [32]         Taking all these facts into consideration, I find that Lyrtech exercised a dominant economic influence over the appellant. ...

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