Search - consideration
Results 11001 - 11010 of 28976 for consideration
Ruling
2020 Ruling 2019-0833091R3 - Supplemental Ruling
On XXXXXXXXXX, CanLP 7 redeemed XXXXXXXXXX units owned by Cansub 4 in consideration for $XXXXXXXXXX, such amount being equal to the aggregate FMV of the units immediately before the redemption. ... On XXXXXXXXXX, Cansub 4 sold all its class D preferred shares of Cansub 3 to CanLP 11 in consideration for $XXXXXXXXXX, such amount being equal to the aggregate FMV of the Cansub 3 shares immediately before the sale. ... As consideration for the Distribution Property, TC ULC will: (a) assume certain liabilities (the TC ULC Assumed Liabilities) of DC ULC, including a portion of the Newco XXXXXXXXXX Loan (the Newco XXXXXXXXXX Assumed Loan). ...
Ruling
2022 Ruling 2022-0947921R3 - Post-mortem tax planning
Reasons: 1) Non-share consideration does not exceed the adjusted cost base of the transferred shares; 2) In accordance with the Act and consistent with CRA's published positions. ... In consideration for the redemption of the Class A special shares, Opco will issue PN1 to the Estate. ... The Estate will dispose of the Remaining Shares to Newco in consideration for PN2 and XXXXXXXXXX Class 1 common shares of the capital stock of Newco. ...
Ruling
2023 Ruling 2023-0969661R3 - Post-mortem Pipeline
Child 1 exchanged his XXXXXXXXXX Opco Class A Common Shares in consideration for XXXXXXXXXX Opco Class X Common Shares; b. Each of Child 2, Child 5, Child 6 and Child 7 exchanged their XXXXXXXXXX Opco Class A Common Shares in consideration for XXXXXXXXXX Opco Class Y Common Shares; c. ... All of the Opco Class Y Common Shares owned by each of the children’s holding corporations were redeemed in consideration for the Redemption Notes; and e. ...
Ruling
2024 Ruling 2023-0989031R3 - QET Internal Reorganization
(2) Is there an income inclusion as a result of a disposition of a QET interest where the only consideration for the disposition is an assumption of reclamation obligations? ... No amount will be separately received or earned by the Corporation in connection with the transfer of the QET Interest, for which the sole consideration will be the assumption of the Reclamation Obligations by the Partnership. 34. ... For greater certainty, the assumption of the Reclamation Obligations by the Partnership will not be considered additional consideration in respect of the transfer of the XXXXXXXXXX Assets by the Corporation to the Partnership. ...
Ruling
30 November 1996 Ruling 9629733 - BUTTERFLY RULING (XXXXXXXXXX)
On incorporation, Subco1 will issue to DC2 XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ... On incorporation, Parentco will issue to Mother XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ... On incorporation, Subco2 will issue to Parentco XXXXXXXXXX common shares for consideration of $XXXXXXXXXX. ...
Ruling
2003 Ruling 2003-0022393 - Split Up Butterfly
DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee1 for fair market value consideration. ... DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee2 for fair market value consideration. ... DC will purchase for cancellation all of the DC common shares of its capital stock owned by Transferee3 for fair market value consideration. ...
Ruling
2020 Ruling 2020-0844991R3 - Internal Reorganization - 55(3)(a)
GP’s Articles will also be amended to add Class C1 shares, which will be voting shares that are redeemable for the consideration for which they were issued. ... In accordance with subsection 51(1), D will exchange the XXXXXXXXXX Class B shares that he holds in GP in consideration for XXXXXXXXXX Class C1 shares in GP having an aggregate PUC, ACB and FMV of $XXXXXXXXXX. ... D and A or the family trust in favor of A will subscribe for the ManagementCo shares in consideration for a nominal cash consideration. 57. ...
Ruling
2010 Ruling 2009-0332571R3 - Loss consolidation - related or affiliated
As sole consideration, HASub issued Class F preferred shares to each of Mr. ... As sole consideration, HBSub issued Class F preferred shares to each of Mr. ... (b) An unlimited number of Preferred Shares2 that are non-voting, non-participating, redeemable and retractable at any time at the request of the holder for an amount equal to the fair value of the consideration received upon issuance. ...
Ruling
2015 Ruling 2013-0490651R3 - Single-wing Split-up Farm Butterfly
Sibling1 will transfer all of his shares of DC to TC and, as consideration therefor, Sibling1 will receive XXXXXXXXXX Class G preferred shares of TC with an aggregate fair market value equal to the aggregate fair market value, at the time of the transfer, of the DC shares transferred by Sibling1 to TC. ... 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 Share so redeemed. 22. ... As consideration therefor, DC will issue to TC Promissory Note2. TC will accept Promissory Note2 as full payment for the aggregate fair market value of the common shares. 23. ...
Ruling
2015 Ruling 2014-0554231R3 - Split-up Butterfly
Each share will be entitled to a non-cumulative preferential dividend of XXXXXXXXXX of XXXXXXXXXX percent (XXXXXXXXXX%) of the amount of the consideration for which the share was issued. Upon a liquidation of the corporation, the share will be entitled to the consideration for which the share was issued. Each share will be redeemable and retractable for the consideration for which the share was issued (the "Class E shares"). 13. ...