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Ruling

2012 Ruling 2012-0451421R3 - Purchase of Target and bump

On XXXXXXXXXX Parent Subco subscribed for common shares and preferred shares of the capital stock of New Holdco in consideration for XXXXXXXXXX. 48. ... Subco 4 will amend its articles to permit the transfer of an interest and Target Amalco will transfer a XXXXXXXXXX% interest in Subco 4 to Subco 3 for cash consideration. 65. ... The consideration received by Subco 15 on such disposition will be distributed to an intermediary corporation as consideration for the repurchase of Subco 15 shares and will be received by Subco 3 as consideration for the repurchase of shares in the intermediary corporation. ...
Ruling

2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT

The units of itself that REIT #1 shall receive, as described in 51 above, will be cancelled for no consideration. 53. ... The units of itself that REIT #1 shall receive, as described in 62 above, will be cancelled for no consideration. 64. ... The units of itself that REIT #1 shall receive, as described in 73 above, will be cancelled for no consideration. 75. ...
Ruling

2008 Ruling 2008-0267631R3 - income trust, stapled units & elimination of corp

As consideration, Portfolio LP, assumed liabilities and issued XXXXXXXXXX Class B Portfolio LP Units to the various vendors. 21. ... Finance Trust will transfer the Existing Loans to US Subco in consideration for the issuance of the US Subco Note. 43. ... The Fund will incorporate Newco by subscribing for one Newco Common Share for nominal consideration. ...
Ruling

2005 Ruling 2005-0121201R3 - Split-up Butterfly

As consideration therefor, DC will pay $XXXXXXXXXX to Sib2 and $XXXXXXXXXX to the group comprising Child1, Child2 and Child3, jointly. ... The interest-bearing promissory note issued as consideration for this transfer will not be convertible into any other property. ...
Ruling

2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure

The Fund will subscribe for MFT Units for a nominal cash consideration. ... No consideration other than the Fund Units will be received by the Fund and the MFT Unitholders on the redemption of the MFT Units. 30. ... The one MFT Unit held by the Fund will be cancelled for no consideration. ...
Ruling

30 November 1997 Ruling 9800973 - BUTTERFLY RULING (SPIN-OFF)

You have advised us that DC will sell the XXXXXXXXXX Subco2 Preferred Shares for consideration that will consist only of cash or indebtedness that is not convertible into other property, or of any combination thereof, prior to the commencement of the proposed transactions described below. 8. ... On or about XXXXXXXXXX DC disposed of its XXXXXXXXXX% interest in XXXXXXXXXX for consideration consisting of cash in the amount of $XXXXXXXXXX and a non-convertible note receivable in the amount of $XXXXXXXXXX due on XXXXXXXXXX (collectively hereinafter referred to as the Sale Proceeds). ... No other consideration will be received by any DCAmalco Shareholder in respect of the Share Exchange. ...
Ruling

2003 Ruling 2002-0155853 - 55(3)(b)

As consideration for each transfer, Predecessor DC issued to each Trust XXXXXXXXXX Predecessor DC common shares having an aggregate FMV of $XXXXXXXXXX. ... As consideration for each transfer, Predecessor DC issued to each of Father and Mother XXXXXXXXXX Predecessor DC first special shares having a par value of $XXXXXXXXXX and a redemption amount of $XXXXXXXXXX each. ... As sole consideration, DC will issue to each particular DC Shareholder a number of the DC Class A Preference Shares having an aggregate FMV, redemption and retraction amount equal to the aggregate FMV of the DC shares that were transferred by the particular DC Shareholder to DC. ...
Ruling

2004 Ruling 2003-0043751R3 - sequential butterflies

As consideration for such sale, the third party granted a mortgage against the Lands to DC1 ("Mortgage Receivable"). ... As consideration for the 2004 Property, the Purchaser will pay DC1 cash of $XXXXXXXXXX and grant to DC1 a first mortgage ("First Mortgage") against the 2004 Property in the amount of $XXXXXXXXXX ("2004 Mortgage Receivable"). ... As sole consideration, DC2 will issue to each particular DC1 Shareholder XXXXXXXXXX DC2 Common Shares having an aggregate FMV equal to the aggregate FMV at that time of the DC1 shares that the particular DC1 Shareholder so transferred to DC2. ...
Ruling

2004 Ruling 2004-0082691R3 - Public Company spin-off

Options to each of X Co. and Newco in consideration for the issuance to the particular holder of New X Co. ... Redemption Amounts and will issue to Y Co. in consideration therefor the X Co. ... Redemption Amounts and will issue to X Co. in consideration therefor the Y Co. ...
Ruling

2000 Ruling 1999-0010893 - XXXXXXXXXX ruling

A XXXXXXXXXX Bare Trustee (on behalf of Child A) XXXXXXXXXX XXXXXXXXXX Child A XXXXXXXXXX As sole consideration for the transfer of such shares to Investco A by each of Mr. ... A XXXXXXXXXX Bare Trustee (on behalf of Child D) XXXXXXXXXX XXXXXXXXXX As sole consideration for the transfer of such shares to Investco D by each of Mr. ... For greater certainty, no non-share consideration will be paid by Aco as part of this share exchange. 17. ...

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