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Ruling

2011 Ruling 2011-0394671R3 - Charitable Donation of Publicly Listed Shares

The redemption price of each class D preferred share of the capital stock of Holdco1 will be an amount equal to (i) the monetary consideration received by the corporation upon the issuance of such share (denominated in the currency in which such consideration was paid to the corporation), if such share has been issued for money, less any amount distributed in respect of such share on a reduction of the stated capital account maintained in respect of the class D preferred shares; or (ii) the FMV of the consideration received by the corporation (including, without limitation, shares of another class of the corporation) upon the issuance of such share, if such share has been issued for a consideration other than money, less any amount distributed in respect of such share on a reduction of the stated capital account maintained in respect of the class D preferred shares. 19. The statutes of Holdco1 provides for a price adjustment clause in respect of the FMV of the consideration received by the corporation upon the issuance of its class D preferred shares. 20. ... At the time of its incorporation, Foreignco1 had issued to Holdco2 XXXXXXXXXX class A common shares and XXXXXXXXXX common shares for a consideration of $ XXXXXXXXXX and $ XXXXXXXXXX, respectively. ...
Ruling

2012 Ruling 2010-0391271R3 - Deemed Limited Partner & Specified Member

On XXXXXXXXXX Parent B incorporated BCo under the CBCA and subscribed for common shares for nominal cash consideration. 10. ... On XXXXXXXXXX, Parent C incorporated CCo under the CBCA and subscribed for common shares for nominal cash consideration. 16. ... (b) The following amounts will be payable under the Bipartite Agreement (the "Consideration Payments"): (i) From the date of XXXXXXXXXX. ...
Ruling

2012 Ruling 2011-0408991R3 - Split-up butterfly

Consideration for the transfer of the XXXXXXXXXX Common Shares of the capital stock of DC will consist of XXXXXXXXXX Common Shares of the capital stock of TC with a FMV equal to the FMV of the XXXXXXXXXX Common Shares of the capital stock of DC transferred. ... Consideration for the transfer of the XXXXXXXXXX Class B Special Shares of the capital stock of DC will consist of XXXXXXXXXX Class B Special Shares of the capital stock of TC with a FMV and Class B Redemption Amount equal to the FMV of the XXXXXXXXXX Class B Special Shares of the capital stock of DC transferred. ...
Ruling

2009 Ruling 2009-0308611R3 - Alter Ego Trust

The rights and restrictions attached to the New Aco Shares will provide that: (a) the shares will be redeemable and retractable preferred shares, without par value; (b) the aggregate redemption price of such shares shall be equal to the fair market value of any consideration received by Aco in consideration for the issuance of such shares; and (c) upon the issuance of such shares, the directors of Aco shall add such amount as they shall determine to the stated capital account, provided that such amount shall equal but not exceed the fair market value of the consideration received for the issuance of such shares. 14. ... The rights and restrictions attached to the New Bco Shares will provide that: (a) the shares will be redeemable and retractable preferred shares, without par value; (b) the aggregate redemption price of such shares shall be equal to the fair market value of any consideration received by Bco in consideration for the issuance of such shares; and (c) upon the issuance of such shares, the directors of Bco shall add such amount as they shall determine to the stated capital account, provided that such amount shall equal but not exceed the fair market value of the consideration received for the issuance of such shares. 15. ... In addition, the Aco Share Exchange Agreement will provide that cash consideration will be received by the AE Trust in exchange for the Subject Aco Shares in order to prevent section 51 from applying to the exchange, which would otherwise preclude the AE Trust from being deemed to have received a dividend from Aco by virtue of the reduction to the paid-up capital of the New Aco Shares that would be made under subsection 51(3). ...
Ruling

2008 Ruling 2007-0249451R3 - Split-up butterfly

Each TC will subscribe for one Subco Common Share of its respective Subco for cash consideration of $XXXXXXXXXX upon its incorporation. 6. ... As sole consideration for the transfer, TC XXXXXXXXXX will each issue one TC Common Share to Child XXXXXXXXXX, respectively, which will be the only issued share of each TC. ... As consideration for each such purchase, DC will assign and transfer the XXXXXXXXXX Each such TC will accept its respective Subco Redemption Note as full satisfaction for the purchase price of its DC Common Share so purchased with the risk of such note being dishonored. 14. ...
Ruling

2005 Ruling 2004-0070981R3 - Conversion to MFT

The shares of Sub 1 previously traded on the XXXXXXXXXX Stock Exchange and were acquired by Opco for consideration of cash and Opco Common Shares in XXXXXXXXXX. 3. ... AcquisitionCo will acquire Opco Common Shares (other than Option Common Shares) from Resident Shareholders, in consideration for the following: (a) common shares of AcquisitionCo (as to XXXXXXXXXX% of the consideration); and (b) a series of notes (the "Trust Notes") which have a principal amount in the aggregate equal to XXXXXXXXXX% of the fair market value of the Opco Common Shares received. 24. ... In consideration for a reduction of the amount due under the Trust Notes, AcquisitionCo will transfer the Royalty to the Trust. ...
Ruling

2005 Ruling 2004-0095431R3 - Spin-off butterfly

Also in XXXXXXXXXX, Opco transferred certain of its XXXXXXXXXX inventory to Realco and received as consideration a non-interest-bearing promissory note receivable from Realco. ... As consideration, Opco will issue to Newco a demand promissory note with a principal amount and fair market value equal to the aggregate fair market value of the repurchased shares. ... As consideration, Newco will issue to Opco a demand promissory note with a principal amount and fair market value equal to the aggregate redemption amount of the redeemed shares. ...
Ruling

2016 Ruling 2016-0635101R3 - 55(3)(a) Spin-Off to Use Parent Losses

Parent will transfer all of the Subco Old Preferred Shares to Subco in consideration for one newly issued Subco Old Common Share XXXXXXXXXX. ... Each Newco Preferred Share will be a non-voting share and will be redeemable and retractable for an amount equal to the FMV of the consideration received by Newco in exchange for the issuance of such Newco Preferred Share. ... Parent will transfer its Subco A Preferred Shares to Newco, in consideration for XXXXXXXXXX newly issued common shares of Newco. ...
Ruling

2017 Ruling 2017-0693271R3 - Split-Up Butterfly

As consideration for the property transferred by DC Amalco to Subco1 and Subco2, Subco1 and Subco2, as the case may be, will: a) assume an amount of DC Amalco’s existing liabilities; and b) issue to DC Amalco the Subco1 Butterfly Shares and Subco2 Butterfly Shares. 30. ... The agreed amount in respect of each eligible property so transferred will not be greater than the FMV of such property nor will it be less than the FMV, at the time of disposition, of the consideration therefor other than shares of the capital stock of that corporation or a right to receive such shares. ... As consideration for the redemption, Subco1 will issue the Subco1 Redemption Note and Subco2 will issue the Subco2 Redemption Note as full payment for the aggregate redemption amount of the shares so redeemed. 33. ...
Ruling

30 November 1995 Ruling 9632593 - DIVISIVE REORGANIZATION

As sole consideration for such transfer, XXXXXXXXXX will issue to XXXXXXXXXX Class XXXXXXXXXX Special Shares with a fair market value equal to the fair market value at the time of the transfer of the shares transferred by XXXXXXXXXX. ... As sole consideration for such transfers, XXXXXXXXXX will issue to XXXXXXXXXX Class XXXXXXXXXX Special Shares with a fair market value equal to the fair market value at the time of the transfer of the shares transferred by XXXXXXXXXX. ... In consideration for such transfers, each of XXXXXXXXXX will issue Special Shares and assume a portion of the liabilities of Amalco. ...

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