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Ruling

1998 Ruling 9824483 - CORPORATE REORGANIZATION

In consideration for such transfer XXXXXXXXXX will issue common shares with a fair market value equal to the fair market value of the XXXXXXXXXX preferred shares transferred to XXXXXXXXXX at the time of the transfer. ... In consideration for such transfer Newco will issue Class A common shares with an aggregate fair market value equal to the fair market value, at the time of the transfer, of the Class A shares of Amalco transferred to Newco. 62. ... In consideration for such transfer Newco will issue Class B common shares with an aggregate fair market value equal to the fair market value, at the time of the transfer, of the Class A shares of Amalco transferred to Newco. 64. ...
Ruling

1999 Ruling 9902483 - BUTTERFLY RULING

The Trust will sell at fair market value its XXXXXXXXXX common shares of DC for cash consideration to Individual A. ... Xco and Yco will subscribe for 1 common share of Subco1 and Subco2, respectively, for a cash consideration of $XXXXXXXXXX. ... Before the transfers of property as described in paragraph 15 below, DC will sell the agent securities at fair market value for cash consideration. 13. ...
Ruling

2021 Ruling 2020-0863171R3 - Gross basis split-up Butterfly

On incorporation, Holdco1 will subscribe for XXXXXXXXXX common share of Nominee1 for nominal consideration. ... On incorporation, Holdco2 will subscribe for XXXXXXXXXX common share of Nominee2 for nominal consideration. ... On incorporation Holdco1 will subscribe for XXXXXXXXXX common shares in consideration for a cash payment of $XXXXXXXXXX. 27. ...
Ruling

2022 Ruling 2021-0920791R3 - Butterfly Reorganization

Sibling 1 will transfer her XXXXXXXXXX common shares of DC to TC1 in exchange for TC1 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC XXXXXXXXXX transferred. 30. Sibling 2 will transfer her XXXXXXXXXX common shares of DC to TC2 in exchange for TC2 issuing XXXXXXXXXX of its common shares as sole consideration therefore having an aggregate FMV equal to the aggregate FMV of the XXXXXXXXXX common shares of DC XXXXXXXXXX transferred. 31. ... 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. ...
Ruling

2000 Ruling 2000-0003253 - Safe income

In XXXXXXXXXX, Xco and Yco incorporated Bco and each subscribed for XXXXXXXXXX Bco common shares for a cash consideration of $XXXXXXXXXX. ... As sole consideration for such transfer, Dco will issue XXXXXXXXXX of its XXXXXXXXXX common shares to Eco, having an aggregate FMV equal to the FMV of the XXXXXXXXXX Holdco XXXXXXXXXX shares so transferred to Dco. ... As sole consideration for such transfer, Opco will issue XXXXXXXXXX Opco XXXXXXXXXX shares having an aggregate FMV equal to the FMV of the XXXXXXXXXX Holdco XXXXXXXXXX shares so transferred to Opco as described herein. ...
Ruling

2008 Ruling 2008-0266441R3 - Debt Forgiveness

ACO will transfer, at FMV, to BCO its XXXXXXXXXX preferred share of Newco in consideration for additional common shares of BCO. ... Debtor will contribute all of its shares of Debtor's Sub #2 to the share capital of New BCO USA for no consideration. 55. ... ACO will subscribe for additional common shares of BCO in consideration for nominal cash consideration and a transfer to BCO of the undertaking described in 57(c) above. 59. ...
Ruling

1999 Ruling 9907793 - BUTTERFLY RULING

As the sole consideration, A Ltd. will issue additional common shares of A Ltd. to each of Mr. ... As the sole consideration, B Ltd. will issue additional common shares of B Ltd. to each of Mr. ... As the sole consideration, C Ltd. will issue additional common shares of C Ltd. to each of Mr. ...
Ruling

1999 Ruling 9924993 - XXXXXXXXXX BUTTERFLY - DIVISIVE REORGANIZATION

C, in XXXXXXXXXX and as consideration for certain property which the three brothers (collectively, the "Brothers") had transferred to DC. ... B in consideration for the payment by him of a cash subscription price of $XXXXXXXXXX, and XXXXXXXXXX common shares were issued to Mr. ... E, as the case may be, and issued common shares of its capital stock to its shareholder as consideration for the transfer of such Cco shares. ...
Ruling

2000 Ruling 1999-0010723 - sequential butterfly reorganizations

TC previously transferred a subject property to DC and received DC non-voting preferred shares as consideration. ... The fair market value of the property received by each of DC2 and DC3 as consideration for each such share was not less than the specified amount, being $XXXXXXXXXX. ... As consideration for such transfer, Individual A received XXXXXXXXXX preferred shares of DC2 having an aggregate fair market value and redemption amount equal to the fair market value at the time of the transfer of the Subco shares so transferred to DC2 less the amount of non-share consideration received by Individual A. ...
Ruling

2021 Ruling 2021-0889411R3 - Multi-wing net asset butterfly reorganization

A will transfer the A Shares to ACo in consideration for XXXXXXXXXX common shares in ACo having an aggregate FMV equal to the aggregate FMV of the A Shares. ... B will transfer the B Shares to BCo in consideration for XXXXXXXXXX common shares in BCo having an aggregate FMV equal to the aggregate FMV of the B Shares. ... C will transfer the C Shares to CCo in consideration for XXXXXXXXXX common shares in CCo having an aggregate FMV equal to the aggregate FMV of the C Shares. ...

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