Search - consideration

Proposed transactions Bco will incorporate a new wholly-owned subsidiary (“Lossco”) and subscribe for Lossco common shares for nominal consideration. Cco will incorporate a new wholly-owned subsidiary (“Newco 1”) and subscribe for Newco 1 common shares for nominal consideration. ...

Ss. 87(9)(a.4) and (c) apply so that the cost of the shares of Amalco held by Parentco are not derived from the value of the consideration given. ... CRA indicated that in Scenario 1, the shares received by Parentco from Amalco are subject to the application of ss. 87(9)(a.4) and (c), so that the cost of the shares of Amalco held by Parentco will not be derived from the value of the consideration given (that is the shares issued by Parentco to acquire the shares of Amalco) to the former shareholders of Targetco. ...

Preliminary transactions After redeeming the Class B and C preferred shares through the issuance of demand promissory notes (with no resulting deemed dividend or capital gain to the estate), ACo will purchase for cancellation (in consideration for issuing a demand promissory note) a sufficient such number of its Class A shares to result in a refund of its eligible refundable dividend tax on hand, or its non-eligible refundable dividend tax on hand, balances. ... Proposed transactions The Estate will transfer its remaining Class A shares (electing under s. 85(1)) to a newly-incorporated corporation formed by it (“Newco”) in consideration mostly for a note (the “Note 6”) with a principal amount and FMV equal to the lesser of such shares’ current FMV and their (stepped-up) ACB, and for a Class A (common) share of Newco. ...

Preliminary transactions Opco redeemed Class E shares in consideration for Note 1 and designated the resulting deemed dividend as an eligible dividend, with the estate carrying back the resulting capital loss to it under s. 164(6). ... Proposed transactions The estate will transfer its Class A shares of Opco 2 to a corporation newly incorporated by it (“Newco”) in consideration for a note (“Note 5”) and for Class B non-voting redeemable retractable shares, electing under s. 85(1) and with a price adjustment clause. ...

Proposed transactions The estate will transfer its Class A and Class E shares of the Corporation to a newly-incorporated corporation (“Newco” – whose voting common shares are held by it) in consideration for Class A common shares and a Newco and two non-interest-bearing notes (“Note 1” and “Note 2”), electing under s. 85(1). ... Trusts 1, 2 and 3 will transfer their Class J shares of the Corporation to Newco in consideration for Class F shares of Newco, electing under s. 85(1). ...

They then implemented a divisive reorganization of Opco under which B disposed of her Opco common shares to Newco (newly-incorporated by her) in consideration for Newco common shares, Opco disposed of a portion of its business property to Newco in consideration for Newco preferred shares and the two shareholdings were cross-redeemed for notes that were then set off. ...

The Corporation will redeem the Class A Preferred Shares in consideration for a demand noninterest bearing promissory note, designate a portion (not exceeding its GRIP account) as an eligible dividend pursuant to s. 89(14) and report a resulting capital loss, which will be carried back under s. 164(6). ... The Estate will transfer the Class A Common Shares to a “Newco” formed by it in consideration for Newco common shares, electing under s. 85(1). ...

Fund LP will transfer the Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new LP (New LP – formed by General Partner LP as general partner and Fund LP as limited partner, and) in consideration for units of New LP, with similar terms to Fund LP, except that distributions are solely in proportion to the number of units held. ... The other former partners will sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...

Fund LP transfers its Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new subsidiary LP (New LP) in consideration for the plain-vanilla units. ... The other former partners sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...

Situation 1 Subsequent to Child B’s death, Parent A transfers the policy to B’s Spouse for no consideration. ... Provided that B’s Spouse acquired this interest without consideration, it is our view that subsection 148(8) of the Act would apply to the transfer of the interest in the Policy from Parent A to B’s Spouse, such that Parent A would be deemed to have disposed of the interest in the Policy for proceeds of the disposition equal to Parent A’s ACB of the interest immediately before the transfer, and B’s Spouse will be deemed to have acquired the interest in the Policy at a cost equal to those proceeds. ...