Search - consideration

Results 11061 - 11070 of 28974 for consideration

Grimes v. The Queen, 2016 TCC 280

I therefore think that the market price, in a case like that under consideration, where it is shown to have been consistent, determines the fair market value of the shares. ... He was of the view that this consideration arises out of the requirement to ascertain the “cash equivalents” of those shares. ... However, I note that another factor taken into consideration by Mr. Blackman is the lack of control conferred by the Class A Common Share. ...

Côté v. The Queen, docket 92-2773-IT-G

This difference was due to the fact that the works of art were purchased at auctions or were offered by artists or by persons who owned the works and were selling them off for a cash consideration. [9] Mr. ... In the case at bar, the evidence is clear that neither of the appellants received any consideration whatsoever from the organizations to which the property was to be given. ... A receipt obtained from the recipient organization cannot be viewed as consideration even though the taxpayer must file the receipt to be entitled to the deduction for gifts. ...

Coté v. R., [1999] 3 CTC 2373

Ownership of property was transferred between the parties, and no consideration was paid by the charity that received the property. ... The fact that the donors were able to incidentally derive a monetary benefit from the transactions is of no consequence, since the donees paid no consideration. ... No one purchased tax receipts, and the appellants did not obtain any consideration or anything else from the registered organizations. ...

2013 Ruling 2013-0476331R3 - Split-up Butterfly

The redemption value of the TC1 Preferred Shares will be equal to the value of the assets received in exchange for the shares, less the value of any other consideration issued for the assets received. ... The redemption value of the TC Preferred Shares will be equal to the value of the assets received in exchange for the shares, less the value of any other consideration issued for the assets received. ... Each of the TCs will redeem the TC Preferred Shares that were issued to DC as consideration for the transfer of property described above in Paragraph 20. ...

2015 Ruling 2015-0588551R3 - Post-Mortem Planning

The Class “E” Preferred shares are non-voting, non-participating, entitling the holder to a discretionary fixed and non-cumulative dividend at a rate not exceeding XXXXXXXXXX% per year of the redemption amount and redeemable and retractable at an amount equal to the excess of the FMV of the consideration received for their issuance less the FMV of any non-share consideration received in partial consideration therefor plus the amount of any dividends declared thereon but unpaid. 8. ... TRUST will subscribe for XXXXXXXXXX Class “A” Common shares of the capital stock of NEWCO for a consideration of $XXXXXXXXXX. ... TRUST will receive as consideration the NEWCO-HOLDCO 1 NOTE 3 issued by NEWCO for an amount equal to the FMV of the Class “E” Preferred share of the capital stock of HOLDCO 1 as at the date of A’s death ($XXXXXXXXXX). ...

2005 Ruling 2005-0126801R3 - Income Trust

Each of the Tax-Deferred Shareholders will sell a portion of its common shares in Holdings to Acquireco 1 in consideration for Exchangeable Shares of Acquireco 1 (and corresponding Special Voting Units), which will reflect the retained interest of the Tax-Deferred Shareholders in the Fund. ... The consideration received by each of the Existing Shareholders (as described above) for the shares that it held in Holdings will reflect the fair market value of such Shares. 37. ... The Fund will transfer the common shares and the Class A preferred shares of Holdings held by it to Acquireco 2 in consideration for common shares and debt issued by Acquireco 2. ...

30 November 1995 Ruling 9620343 - XXXXXXXXXX BUTERFLY RULING (NO NEW ISSUES)

Other than the share consideration described above, no other consideration will be received by XXXXXXXXXX as a consequence of the amalgamation. ... As sole consideration for each such transfer, XXXXXXXXXX will issue to XXXXXXXXXX, respectively, XXXXXXXXXX common shares and XXXXXXXXXX Class XXXXXXXXXX preferred shares that are redeemable and retractable in aggregate at an amount equal to the fair market value of the special shares of Amalco transferred therefor. ...

2000 Ruling 2000-0011353 - Butterfly Arrangement

During the year ended XXXXXXXXXX common shares were issued by Canco upon the exercise of stock options for total cash consideration of $XXXXXXXXXX. ... On incorporation Canco subscribed for one common share of NewCanco for nominal consideration. ... As sole consideration for such transfer, NewCanco will issue to Canco a non-interest bearing demand promissory note with a principal amount and FMV equal to the FMV of the assets so transferred. 23. ...

2018 Ruling 2018-0749491R3 - 55(3)(a) Reorganization

On the day of the incorporation of TC2: a) Parent will subscribe for XXXXXXXXXX TC2 Voting Shares for cash consideration of $XXXXXXXXXX; and b) Child 2 will subscribe for XXXXXXXXXX TC2 Common Shares for cash consideration of $XXXXXXXXXX. 17. On the day of the incorporation of TC3: a) Parent will subscribe for XXXXXXXXXX TC3 Voting Shares for cash consideration of $XXXXXXXXXX; and b) Child 3 will subscribe for XXXXXXXXXX TC3 Common Shares for cash consideration of $XXXXXXXXXX. 18. On the day of the incorporation of TC4: a) Parent will subscribe for XXXXXXXXXX TC4 Voting Shares for cash consideration of $XXXXXXXXXX; and b) Child 3 will subscribe for XXXXXXXXXX TC4 Common Shares for cash consideration of $XXXXXXXXXX. 19. ...

2019 Ruling 2018-0790021R3 - Split-Up Butterfly

The aggregate FMV of the shares will be equal to the FMV of the property received by the corporation less any non-share consideration received for the issuance of such shares. 19. ... A will transfer all of his DCAmalco Shares to TC1 for sole consideration consisting of a number of Class “A” Common Shares of TC1. ... B will transfer all of his DCAmalco Shares to TC2 for sole consideration consisting of a number of Class “A” Common Shares of TC2. ...

You are here