Search - consideration
Results 12941 - 12950 of 28851 for consideration
Ruling
2006 Ruling 2006-0197501R3 - Multiple-wing Butterfly
Specifically, upon the amalgamation, DC Amalco will issue XXXXXXXXXX common shares ("DC Amalco Common Shares") to each of Sibling1, Sibling2 and Sibling3 as sole consideration for the DC1 Common Shares and DC2 Common Shares that were owned by each of Sibling1, Sibling2 and Sibling3 immediately before the amalgamation. 11. ... As consideration therefor, Sibling1Co will issue XXXXXXXXXX of its Class A Shares to Sibling1 having an aggregate fair market value equal to the aggregate fair market value of the XXXXXXXXXX DC Amalco Common Shares transferred to SiblingCo1. ... As consideration for such redemption, Sibling1Co, Sibling2Co, and Sibling3Co, as the case may be, will issue a non-interest bearing demand promissory note to DC Amalco having a principal amount and fair market value equal to the aggregate fair market value of its Class E Shares that are being redeemed. ...
Ruling
2015 Ruling 2014-0548491R3 - Split-up XXXXXXXXXX Butterfly
As consideration for the transfer of the shares described in Paragraph 28, ACo. will issue XXXXXXXXXX Class A common voting shares of its capital stock to Mr. ... As consideration for the transfer of the shares described in Paragraph 32, BCo. will issue XXXXXXXXXX Class A common voting shares of its capital stock to Mr. ... The amount added to the stated capital account for the Class F preferred non-voting shares issued by ACo. as partial consideration for the transferred property will be the maximum amount permitted to be added to the PUC of the Class F preferred non-voting shares having reference to subsection 85(2.1). 45. ...
Ruling
2012 Ruling 2012-0452821R3 - Forgiveness of debt
In XXXXXXXXXX, Aco transferred to XXXXXXXXXX some of the Bco Notes in consideration for the issuance by XXXXXXXXXX of additional common shares. ... Prior to the Proposed Transactions contemplated in the Arrangement, Bco will cancel its preferred shares owned by XXXXXXXXXX and Dco for no consideration. 36. ... Aco will transfer to Bco its common shares of Newco1 in consideration for a nominal number of common shares of Bco. 44. ...
Ruling
2014 Ruling 2011-0415811R3 - Internal reorganization
In XXXXXXXXXX and XXXXXXXXXX, Parent subscribed for additional Subco 2 common shares for cash consideration of approximately $XXXXXXXXXX. 19. ... As sole consideration for the transfer, Can Holdco will issue to Subco 3 Can Holdco Non-Convertible Series B Shares having an aggregate redemption amount and FMV equal to the Subco 3-FA 2 Purchase Price. ... As sole consideration for the transfer, Can Holdco will issue to Subco 2 Can Holdco Non-Convertible Series C Shares having an aggregate redemption amount and FMV equal to the Subco 2-FA 1 Purchase Price. ...
Ruling
2013 Ruling 2013-0502921R3 - Split-Up Butterfly - Farm
In consideration for this transfer, TC1 will issue to Son1 Class C Shares having an aggregate Class C Redemption Amount and FMV equal to the aggregate FMV of the DC-A Shares and the DC-D Shares transferred. 29. ... In consideration for this transfer, TC2 will issue to Son2 Class C Shares having an aggregate Class C Redemption Amount and FMV equal to the aggregate FMV of the DC-A Shares and the DC-D Shares transferred. 30. ... In consideration for this transfer, TC3 will issue to Mother Class C Shares having an aggregate Class C Redemption Amount and FMV equal to the aggregate FMV of the DC-A Shares and the DC-D Shares transferred. 31. ...
Ruling
2009 Ruling 2008-0284591R3 - Split-up Butterfly
In consideration for the transfer, TC1-Sub will assume any current liabilities of DC relating to the investment portfolio and issue TC1-Sub Preferred Shares to DC. The fair market value of the consideration given by TC1-Sub will equal the total fair market value of the property transferred to TC1-Sub, determined at the time of the transfer. ... None of the TC2 Preferred Shares will be issued for consideration that includes a taxable preferred share. 40. ...
Ruling
2010 Ruling 2009-0346671R3 - Standard Split-up Butterfly
Consideration for the transfer of the Class "A" common shares of DC will consist of a number of Class "E" preferred shares of TC1 with a FMV and redemption amount equal to the FMV of the Class "A" common shares of DC transferred. ... Consideration for the transfer of the Class "A" common shares of DC will consist of a number of Class "D" preferred shares of TC2 with a FMV and redemption amount equal to the FMV of the Class "A" common shares of DC transferred. ... No consideration of any kind will be paid by DC as a result of such reduction of stated capital. 31. ...
Ruling
2008 Ruling 2006-0212691R3 - paragraph 88(1)(c) bump
(b) In accordance with the applicable partnership agreement, Partnership #1 caused the N Note to be distributed to N in consideration for a reduction in N's capital in Partnership #1 and the N Note was cancelled by operation of law. ... The amount added to the stated capital in respect of the Subco #1 Class A Preferred Shares issued by Subco #1 as consideration for the I #1 will not exceed the amount determined in accordance with "B" of paragraph 85(2.1)(a). ... The amount added to the stated capital in respect of the Subco #2 Class A Preferred Shares issued by Subco #2 as consideration for the I #2 will not exceed the amount determined in accordance with "B" of paragraph 85(2.1)(a). ...
Ruling
2006 Ruling 2005-0141921R3 - Public Company Spin-off
On incorporation, DC will subscribe for common shares of Newco for nominal consideration. 16. ... Any entitlement of a holder of a DC Stock Option to a fraction of a Spinco Common Share will be cancelled for no consideration. ... Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting only of one DC New Common Share and one DC Butterfly Share. ...
Ruling
2002 Ruling 2002-0119293 - Split up Butterfly
On incorporation, Sib1 will subscribe for XXXXXXXXXX Class "A" common shares of TC1 for nominal consideration and Sib2 will subscribe for XXXXXXXXXX Class "A" common shares of TC2 for nominal consideration. 21. ... The consideration paid by TC1 will be: (i) a promissory note equal to the adjusted cost base of the transferred shares (as determined pursuant to section 84.1) minus $XXXXXXXXXX; and (ii) Class "C" preferred shares having an aggregate redemption and retraction amount equal to the amount by which the aggregate fair market value of the transferred shares of DC exceeds the amount of the non-share consideration. ... As consideration for the transfer of DC's property, TC1 and TC2 will each issue XXXXXXXXXX Class "D" preferred shares to DC. ...