Search - consideration
Results 11011 - 11020 of 28976 for consideration
Ruling
2012 Ruling 2012-0440021R3 - Standard split-up butterfly
Sibling2 will purchase the personal residence from DC for fair market value consideration. 12. Sibling2 will purchase the shares of Gasco owned by Sibling1 for fair market value consideration. 13. ... TC1 will sell to TC2, within XXXXXXXXXX days following the completion of the Proposed Transactions described above, its XXXXXXXXXX% interest in the XXXXXXXXXX for fair market value consideration. ...
Ruling
2006 Ruling 2006-0190371R3 - Reorganization of a mutual fund trust - s. 132.2
The Fund will subscribe for one GPCo Common Share, the consideration for which will be $XXXXXXXXXX cash. 15. ... (b) The MFC Class A Shares will, subject to the XXXXXXXXXX: (i) be non-voting shares; (ii) entitle the holder thereof to dividends, as and when declared by the board of directors; (iii) be redeemable at the option of the holder for a redemption price equal to the fair market value of any consideration paid to subscribe for the share on issuance, which redemption price will be payable in cash or satisfied by the transfer of Fund Units; (iv) entitle the holder, without taking further action, to receive the redemption price upon receipt by MFC of a MFC Class A Share; (v) under no circumstances may MFC suspend redemption of a MFC Class A Share; and (vi) on the dissolution of MFC, entitle the holder thereof to the redemption price in preference to any distribution on the MFC Common Shares. ... The Fund will subscribe for one MFC Common Share, the consideration for which will be a cash payment of $XXXXXXXXXX. 19. ...
Ruling
2006 Ruling 2006-0199751R3 - Income Trust Reorganization
The Fund will subscribe for that number of Class A Shares of Newco as is equal to the number of its issued and outstanding Units in consideration for a cash payment estimated at $XXXXXXXXXX per Class A Share (the "Class A Share Subscription Proceeds"). ... No consideration other than Units will be received by the Unitholders on the redemption of the Class A Shares and no consideration other than Units will be received by the Fund on the redemption of the Class B Shares. 30. ... For greater certainty: (i) in respect of each of the Amalco Properties, Amalco's proceeds of disposition of the particular property and the Fund's cost in respect of the property will be determined under paragraph 132.2(1)(c) to be the lesser of the fair market value of the property and the cost amount to Amalco of the property (if the amount agreed upon in respect of the property in the election is not greater than the cost amount); (ii) Amalco's aggregate cost of the Units received by it from the Fund as consideration for the disposition of the Amalco properties will be deemed to be nil, pursuant to subparagraph 132.2(1)(h)(i); (iii) Amalco's aggregate proceeds of disposition of the Units distributed to Unitholders and to the Fund pursuant to the redemptions described in paragraph 28 will be deemed to be nil, pursuant to paragraph 132.2(1)(l)(i); (iv) the proceeds of disposition to a Unitholder of a Class A Share redeemed by Amalco as described in paragraph 28, and the cost to the Unitholder of Units received as consideration for the redemption, will be deemed, pursuant to paragraph 132.2(1)(j), to be equal to the cost amount to the Unitholder of the Class A Share immediately before the Asset Transfer Time; (v) paragraph 132.2(1)(j) will apply on the redemption by Amalco of the Class B Shares held by the Fund in consideration for Units as described in paragraph 28, such that the proceeds of disposition to the Fund of the Class B Shares will be deemed, pursuant to paragraph 132.2(1)(j), to be equal to the cost amount to the Fund of the Class B Shares immediately before Asset Transfer Time, and the Fund will therefore not recognize any income, gain or loss solely as a result of the redemption of the Class B Shares; (vi) pursuant to subsection 131(4) and subparagraph 132.2(1)(o)(i), section 84 will not apply to deem a dividend to be paid by Amalco nor to deem a dividend to be received by any shareholders of Amalco. ...
Ruling
2006 Ruling 2006-0172931R3 - income trust reorganization
Holdco will transfer all its limited partnership interest in Holdings LP to Holdco II in consideration for common shares of Holdco II having a fair market value equal to that of the transferred limited partnership interest, and will cease to be a partner of Holdings LP. ... Amalco MFC and the Fund intend to enter into an agreement of purchase and sale under which Amalco MFC will transfer all of its assets to the Fund in consideration for the Fund assuming its indebtedness, if any, and in consideration for the Fund issuing to Amalco MFC a number of Fund Units with an aggregate fair market value equal to the fair market value of the assets so transferred less the amount of assumed liabilities, if any. ... This will be the only consideration received on the redemption of the Amalco Class A and Amalco Class B shares. ...
Ruling
2005 Ruling 2005-0142491R3 - Split-up butterfly
Aco will file Articles of Amendments to convert the existing authorized, unissued, non-voting Class "D" shares into voting shares which will be redeemable by Aco for an amount equal to the FMV of the amount received by Aco as consideration for the share. 23. ... None of the Class "A" or Class "D" shares will be issued for consideration that includes a taxable preferred share. 33. ... For greater certainty, the agreed amount for any capital property included in the subsection 85(1) election, referred to herein, will not be less than the amount of any liabilities assumed as consideration therefore, and will not exceed the fair market value of each such property. ...
Ruling
2018 Ruling 2017-0714411R3 - Butterfly Reorganization
As consideration for the transfer, TC will issue to Child 2 XXXXXXXXXX TC Common Shares. ... As consideration for the transfer, TC will issue to Mother XXXXXXXXXX TC Class A Shares. ... As consideration for the transfer, TC will issue a non-interest bearing demand promissory note in the principal amount equal to the FMV of the policy (the “TC Insurance Note 2). ...
Ruling
2004 Ruling 2003-0053731R3 - Gross Asset Butterfly
On that same day, Sibling 1 subscribed for XXXXXXXXXX newly authorized Class B Shares and Sibling 2 subscribed for XXXXXXXXXX newly authorized Class C Shares for fair market value consideration. ... The authorized share capital of Sibling 1 Co and Sibling 2 Co will include voting common shares and voting preferred shares, redeemable and retractable for an amount equal to the fair market value of the consideration for which such shares are issued. Sibling 1 will subscribe for XXXXXXXXXX common shares of Sibling 1 Co for an aggregate consideration of $XXXXXXXXXX and Sibling 2 will subscribe for XXXXXXXXXX common shares of Sibling 2 Co for an aggregate consideration of $XXXXXXXXXX. 11. ...
Ruling
2001 Ruling 2000-0050983 - Re-freeze transactions
B Holdco for consideration consisting solely of XXXXXXXXXX Class A common shares of Mrs. ... B Holdco for consideration consisting solely of XXXXXXXXXX Class A common shares of Mr. ... B Holdco for consideration consisting solely of XXXXXXXXXX Class B common shares of Mr. ...
Ruling
1999 Ruling 1999-9914603 - Interest deductibility
LP will advance $XXXXXXXXXX to LPSub in consideration for a promissory note (the "LP Note"). ... LPSub will advance $XXXXXXXXXX to BCO in consideration for a promissory note (the "LPSub Note"). ... In consideration for the deletion of the Option clause in the Contract, the PARTNERSHIP will pay XXXXXXXXXX in cash using the proceeds of the BCO capital contribution. ...
Ruling
2002 Ruling 2001-0083623 - XXXXXXXXXX
The amount that each Holdco will add to its stated capital account in respect of its Holdco Class B Shares under the BCA will equal the aggregate PUC attributable to the Investco Class B Shares it will receive from Parent as consideration for such shares. The amount that each Holdco will add to its stated capital account in respect of its Holdco Class D Shares under the BCA will equal the aggregate PUC attributable to the Investco Class D shares it will receive from Parent as consideration for such shares. 11. ... As sole consideration therefore, Holdco A will issue XXXXXXXXXX Holdco A Common Shares to the Child A Family Trust having an aggregate FMV equal to the FMV of the Common Shares of Investco so received. ...