Search - consideration
Results 10991 - 11000 of 28976 for consideration
Ruling
2003 Ruling 2002-0162673 - Butterfly
W will subscribe for XXXXXXXXXX Class "A" Common Shares of Transferee for nominal consideration. 23. ... As consideration W will assume all of the mortgage indebtedness of the XXXXXXXXXX Property, and for the remainder of the purchase price assign a portion of his shareholder's loan account in DC to S. ... As consideration, Transferee will issue XXXXXXXXXX Class "E" Voting Preferred Shares (the "Transferee Special Preferred Shares") to DC and may assume certain liabilities of DC. ...
Ruling
2004 Ruling 2003-0049423 - Split-Up Butterfly
In consideration for such transfer, Bco will issue to Mrs. L Class B Preference Shares with a fair market value and redemption amount equal to the fair market value at the time of the transfer of the XXXXXXXXXX Class A Preference shares of Aco. ... In consideration for such transfer, Cco will issue to Mrs. M Class B Preference Shares with a fair market value and redemption amount equal to the fair market value at the time of the transfer of the XXXXXXXXXX Class A Preference shares of Aco. ... The Class A Preference shares will specify an amount for the purposes of subsection 191(4), to be designated by a resolution of the directors at the time of their issue not to exceed the fair market value of the consideration received for their issue. ...
Ruling
2001 Ruling 2001-0051623 - Split-Up Butterfly
As consideration for such transfer, Newco will issue additional common shares to Holdco. ... As consideration for such transfers, Jco, Kco, Lco and Mco will issue shares to Mrs. ... The share consideration received by Mrs. J, in particular, will be comprised of one Jco common share. ...
Ruling
2001 Ruling 2001-0077363 - split-up butterfly
In consideration for such transfer, Bco will issue to Mrs. L Class B Preference Shares with a fair market value and redemption amount equal to the fair market value at the time of the transfer of the XXXXXXXXXX Class A preference shares of Aco. ... In consideration for such transfer, Cco will issue to Mrs. V Class B Preference Shares with a fair market value and redemption amount equal to the fair market value at the time of the transfer of the XXXXXXXXXX Class A preference shares of Aco. ... The Class A preference shares will specify an amount, for the purposes of subsection 191(4) to be designated by a resolution of the directors at the time of their issue, not to exceed the fair market value of the consideration received for their issue. ...
Ruling
2001 Ruling 2001-0087753 - split-up butterfly
As sole consideration for such transfer, Holdco1 will issue to Sib1 XXXXXXXXXX common shares and XXXXXXXXXX Class A special shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC transferred to Holdco1. 17. ... As sole consideration for such transfer, Holdco2 will issue to Sib2 XXXXXXXXXX common shares and XXXXXXXXXX Class A special shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC transferred to Holdco2. 18. ... As sole consideration for such transfer, Holdco3 will issue to Sib3 XXXXXXXXXX common shares and XXXXXXXXXX Class A special shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC transferred to Holdco3. 19. ...
Ruling
1998 Ruling 9823723 - BUTTERFLY TRANSFER
As sole consideration for such transfer, Holdco XXXXXXXXXX will issue to XXXXXXXXXX common shares with a fair market value equal to the fair market value at the time of the transfer of the shares transferred by XXXXXXXXXX to Holdco XXXXXXXXXX. ... In consideration for such transfers, each of Subco XXXXXXXXXX and Subco XXXXXXXXXX will issue Class A preferred shares and assume a portion of the liabilities of Amalco. ...
Ruling
1999 Ruling 9818193 - REORGANIZATION, ITAR, SUPERFICIAL LOSS
(b) At the same time as the transaction described above, XXXXXXXXXX will transfer, at fair market value, to XXXXXXXXXX all of her common shares of XXXXXXXXXX and, in consideration therefor, XXXXXXXXXX will receive XXXXXXXXXX common shares of XXXXXXXXXX. ... XXXXXXXXXX will sell the Adjusted Interest to XXXXXXXXXX at its fair market value in consideration for which XXXXXXXXXX will issue a non-interest-bearing promissory note payable at the rate of $XXXXXXXXXX per month to XXXXXXXXXX. ... The Class A shares to be issued to XXXXXXXXXX will be redeemed at an amount not greater than the value of the consideration for which the shares will be issued. 30. ...
Ruling
2018 Ruling 2018-0780201R3 - Post-mortem pipeline
Opco will transfer the Specified Properties to Subco in exchange for consideration consisting solely of XXXXXXXXXX common shares of Subco having a FMV equal to the aggregate FMV of the Specified Properties. ... As sole consideration for the redemption, Opco will issue the Opco Note to the Estate having a principal amount and FMV equal to the redemption amount and FMV of shares being redeemed, being $XXXXXXXXXX. ... The Estate will transfer its XXXXXXXXXX Opco Class B Special shares to Newco in exchange for consideration consisting of: a. ...
Conference
27 October 2020 CTF Roundtable Q. 3, 2020-0861031C6 - Safe income on reorganization
Opco then transferred Asset 2 to Newco in consideration for shares of Newco. ... Opco then transferred shares of Subco2 having an ACB of nil and a FMV of $500 to Newco in consideration for shares of Newco. ...
Ruling
2020 Ruling 2020-0860231R3 - Post-mortem planning
Class C, D, E and F preferred shares that are non-voting, redeemable, retractable, having a redemption amount equal to the FMV of the consideration received. ... For greater certainty, the sum of the principal amount of Note 2 and the PUC of the Class C preferred shares of Newco issued as consideration for the XXXXXXXXXX Class A common shares of Opco so transferred will not exceed the aggregate FMV of the XXXXXXXXXX Class A common shares owned by the Deceased immediately before the Deceased’s death. 20. ... Nothing in this letter should be construed as confirmation, express or implied, that, for the purposes 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. ...