Search - consideration

Results 11021 - 11030 of 28976 for consideration

1999 Ruling 9923993 - REORGANIZATION

This would be required in the course of the intended reorganization since on Aco's acquisition of DC's assets, Aco would issue shares to DC as partial consideration. ... The principal amount of any DC liability assumed in part consideration for a transferred property will not exceed its agreed amount. 26. ... The principal amount of any Aco liability assumed in part consideration for a transferred property will not exceed its agreed amount. 38. ...

2000 Ruling 1999-0012953 - Butterfly; Classfication of Property

As sole consideration for such transfer, Asub will issue to Aco XXXXXXXXXX Common shares of its capital stock. ... As sole consideration for such transfer, Bsub will issue to Bco XXXXXXXXXX Common shares of its capital stock. ... As sole consideration for such transfer, Csub will issue to Cco XXXXXXXXXX Common shares of its capital stock. ...

2021 Ruling 2020-0874961R3 - 55(3)(a) Internal Reorganization

As sole consideration for the transfer, Child 1 will receive XXXXXXXXXX Class A common shares of TC1 having an aggregate FMV equal to the FMV of the DC shares so transferred. ... As sole consideration for the transfer, Child 2 will receive XXXXXXXXXX Class A common shares of TC2 having an aggregate FMV equal to the FMV of the DC shares so transferred. ... As sole consideration for the transfer, Child 3 will receive XXXXXXXXXX Class A common shares of TC3 having an aggregate FMV equal to the FMV of the DC shares so transferred. ...

Bioartificial gel technologies (Bagtech) inc. v. The Queen, 2013 DTC 1048 [at at 228], 2012 TCC 120, aff'd 2013 FCA 164 supra.

The dispute related, rather, to the factors that may be taken into consideration in the determination of whether there is de jure control ... [44] The question that should now be answered is: must the clauses of a USA governing the election of a corporation’s directors be taken into consideration in the determination of de jure control of the corporation? ... [86] To summarize, I am of the opinion: (i) that a unanimous shareholders’ agreement must be taken into consideration for the purposes of paragraph (b) of the definition of the expression “Canadian-controlled private corporation” in subsection 125(7) of the ITA; and (ii) that a restriction on the right of the majority shareholder to elect the directors, set out in a written unanimous shareholders agreement, must be taken into consideration in the determination of the de jure control of a corporation ...

17 February 2012 External T.I. 2011-0428561E5 - 88(1)(c)(vi) Bump Denial Rule

As consideration for these transfers, each of A, B and C receives a promissory note and common or preferred shares of the capital stock of NEWCO. ... If C does not participate in incorporating NEWCO and sells his shares of the capital stock of HOLDCO to A and B at FMV in consideration for cash before the transfer of the shares of HOLDCO to NEWCO, could NEWCO bump the cost of eligible property received from HOLDCO on its winding-up, as C would not receive any of HOLDCO's property? ... However, for the purposes of subparagraph 88(1)(c)(vi), if C receives from A and B property other than property distributed by HOLDCO to NEWCO or substituted property as consideration for the sale of his shares of the capital stock of HOLDCO then the bump denial rule in subparagraph 88(1)(c)(vi) should not be applicable in the Particular Situation. ...

2012 Ruling 2012-0435291R3 - Public Corporation PUC Reduction

The Corporation transferred the Properties to Newco and received, as consideration, common shares of Newco. ... On XXXXXXXXXX, the Corporation sold the common shares of Newco to PurchaseCo at fair market value and, as consideration, PurchaseCo issued XXXXXXXXXX common shares and XXXXXXXXXX special warrants to the Corporation. ... The Corporation will hold an annual general meeting at which time its shareholders will be asked to approve a reduction of the stated capital of its common shares in accordance with the Canada Business Corporations Act, consideration for which will be paid by way of distribution of XXXXXXXXXX common shares of PurchaseCo (pro-rata to the shareholdings of the Corporation). 11. ...

11 October 2013 Roundtable, 2013-0492821C6 F - Question 3 - APFF Round Table

À cette fin, l'autorité compétente du Canada nous a mentionné qu'elle prendrait en considération tous les faits propres à la situation donnée en vue d'évaluer l'importance des liens que la fiducie entretient avec le Canada par rapport aux États-Unis. En plus des facteurs prévus au bulletin d'interprétation IT-447, Résidence d'une fiducie ou succession, l'autorité compétente canadienne pourrait prendre en considération certains des facteurs suivants: la résidence du constituant, la résidence des bénéficiaires, l'emplacement des biens de la fiducie, la raison pour laquelle la fiducie est établie dans une juridiction particulière, etc. Cette liste ne se veut pas exhaustive puisque les faits de chaque cas peuvent justifier différentes considérations, lesquelles pourraient conduire à différentes conclusions et négociations. ...

19 June 2015 External T.I. 2015-0570791E5 - Eligible Dependent, Child Tax Credit, Child Care

After the breakdown of the marriage, in a shared-custody arrangement, the child care expense deduction must give consideration to a number of factors. ... In this respect, it appears that the reference to "set-off" for the purposes of calculating the child support payment suggests that the calculation gives consideration to the maintenance guidelines of your province. ... While all requirements of section 63 of the Act must be met for any claim for child care expenses, in circumstances where there is a breakdown of the marriage and two spouses or common-law partners commence living separate and apart during the year, particular issues merit consideration in determining the amount that each spouse may claim for the child care expense deduction. ...

17 May 2013 Roundtable, 2013-0481421C6 - Transfer of life insurance policy to a retiree

17 May 2013 Roundtable, 2013-0481421C6- Transfer of life insurance policy to a retiree CRA Tags 107 148 Principal Issues: (1) Does subsection 148(7) apply when a corporation transfers a life insurance policy to a senior executive officer who is also a shareholder for no consideration? ... The corporation transfers the policy to the individual for no consideration. ... Question B Could the CRA also confirm what its position is with respect to the computation of the ACB, to an individual, of a life insurance policy in the case where: i) an RCA trust holds an insurance policy on the life of the individual ii) the individual is a beneficiary of the RCA trust and is also a shareholder and senior officer of the corporate employer, iii) the individual does not deal at arm's length with the RCA trust, and iv) the custodian of the RCA transfers the policy to the individual for no consideration. ...

26 February 2014 External T.I. 2013-0487961E5 - Excluded Right or Interest

The ownership of the shares is transferred to the individual for no consideration. ... " The word "issue" means to deliver unissued shares of a corporation, including to deliver unissued shares for no monetary consideration. Therefore, section 7 applies when an employer corporation agrees to sell or issue, to an employee of the corporation or of a corporation with which it does not deal at arm's length, its own shares, at less than fair market value or for no monetary consideration. In this scenario, although there is a vesting period between the time when the right to receive a number of shares are first granted to the individual, and the time when the rights vest and the shares are issued to the employee, it is the "right" to such shares which is of relevance to the definition of "excluded right or interest" in subsection 128.1(10) of the Act. ...

You are here