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Results 21391 - 21400 of 28851 for consideration
Ruling

2002 Ruling 2002-0149813 - Stock Split and Amalgamation

Upon the amalgamation described in paragraph 11 above, provided that the terms and conditions of the Amalco Dividend Shares are substantially the same as the terms and conditions of the Bco Dividend Shares, subsection 87(4.2) will apply for the purposes of applying Parts IV.I and VI.I and the definitions "short-term preferred share" and "taxable preferred share" such that: (i) for the purposes of paragraphs 191(4)(d) and (e), the Amalco Dividend Shares will be deemed to have been issued for the same consideration as that for which the Bco Dividend Share was issued and to have been issued for the purpose for which the Bco Dividend Share was issued; and (ii) for the purposes of subsection 191(4), the Amalco Dividend Share will be deemed to have been issued for consideration having a fair market value equal to the consideration for which the Bco Dividend Share was issued. ...
Ruling

2002 Ruling 2002-0136333 - 32-Year rule family trust

B's behalf, a renunciation to release and surrender her contingent interest in Trust #1 for no consideration. ... B's behalf, a renunciation to release and surrender her contingent interest in Trust #2 for no consideration. ... Child C will execute the disclaimer, renunciation and surrender for no consideration. ...
Ruling

1999 Ruling 991426A - RETURN OF PUC BY PUBLIC CORPORATION

In consideration for the transfer of the Purchased Assets, B Co. will assume the accounts payable and accrued liabilities relating to XXXXXXXXXX and will issue to A Co. ... Upon the sale of the Purchased Assets to B Co., A Co. will pay to B Co. an amount XXXXXXXXXX as consideration for B Co. assuming the obligations of A Co. ... Provided that A Co. has included or will have included an amount in respect of the undertakings relating to its obligations XXXXXXXXXX as described in paragraph 17 above, in computing its income from its business pursuant to paragraph 12(1)(a) of the Act for the taxation year which includes the time of the transfer of assets described in paragraph 16 above or any preceding taxation year, the payment made by A Co. to B Co. in consideration for the assumption by B Co. of those undertakings, to the extent that the payment is reasonable: (i) may, pursuant to paragraph 20(24)(a) of the Act, be deducted in computing the income of A Co. for its fiscal period in which the payment takes place; and (ii) will, pursuant to paragraph 20(24)(b) of the Act, be deemed to be an amount described in paragraph 12(1)(a) thereof in respect of B Co. ...
Ruling

1999 Ruling 9927193 - FILM RULING

In consideration for arranging the Primary Loans and the Secondary Loans, XXXXXXXXXX will be entitled to receive a fee (the "Loan Arrangement Fee") from each Limited Partner, the amount of which will be equal to the fair market value of such services estimated to be approximately $XXXXXXXXXX per Unit purchased by such Limited Partner. 19. ... The XXXXXXXXXX Partnership will enter into an agreement (the "XXXXXXXXXX Services Agreement") with the XXXXXXXXXX to provide the services and facilities necessary XXXXXXXXXX (the "XXXXXXXXXX Services") in consideration for the XXXXXXXXXX Fee (as defined below in paragraph 26). ... In consideration for providing the XXXXXXXXXX Services, the XXXXXXXXXX Partnership will be entitled to receive a fee (the "XXXXXXXXXX Fee") from the XXXXXXXXXX. ...
Ruling

2000 Ruling 1999-0013143 - 21-Year Rule - Trusts

The Child C XXXXXXXXXX Trust will then redeem the XXXXXXXXXX Preferred Shares issued to it and in consideration therefor will receive a demand, non-interest bearing promissory note of Yco with a principal amount and fair market value equal to the redemption value of the XXXXXXXXXX Preferred Shares being redeemed. ... The Child A XXXXXXXXXX Trust will then redeem the XXXXXXXXXX Preferred Shares issued to it and in consideration therefor will receive a demand, non-interest bearing promissory note of Yco with a principal amount and fair market value equal to the redemption value of the XXXXXXXXXX Preferred Shares being redeemed. ... Each XXXXXXXXXX Trust will receive as consideration for the Transferred Assets, XXXXXXXXXX common shares of its respective Holdco with a par value of $XXXXXXXXXX per share and a total fair market value equal to the fair market value of the Transferred Assets. ...
Ruling

1998 Ruling 9823003 - ROUTINE SPLIT-UP BUTTERFLY

In consideration of such transfer, XXXXXXXXXX will assume one half of the liabilities of XXXXXXXXXX and issue XXXXXXXXXX Class A Preference Shares having an aggregate redemption and retraction amount and fair market value equal to the amount by which the fair market value of the transferred properties that will be received by XXXXXXXXXX exceeds the aggregate amount of the liabilities assumed by XXXXXXXXXX. ... In consideration, XXXXXXXXXX will issue to each of XXXXXXXXXX a non-interest-bearing demand promissory note ("Notes 3 and 4") having a principal amount equal to the fair market value of the XXXXXXXXXX Common Shares so purchased. 33. ...
Ruling

1998 Ruling 9821433 - ROYALTY TRUST; MUTUAL FUND

Management provides management services to XXXXXXXXXX in consideration of a management fee equal to a percentage of the aggregate of the net XXXXXXXXXX revenue and tax credits and income from certain Permitted Investments, other than the royalty. ... Royalty Units have historically been issued for the same amount of consideration as for the Trust Units. ... XXXXXXXXXX and the Trust will execute a Facility Agreement of Purchase and Sale whereby XXXXXXXXXX will sell beneficial ownership of the Facilities and the Miscellaneous Interests to the Trust for aggregate consideration of approximately $XXXXXXXXXX. ...
Ruling

1999 Ruling 9814003 F - UNDIVIDED INTEREST-NET VALUE-1 WING BUTTERFLY

Après avoir pris en considération le passif à court terme de Cédante, la JVM des Liquidités de Cédante, aux fins de la définition du terme «attribution» au paragraphe 55(1) de la Loi sera nulle. ... Gestion souscrira à XXXXXXXXXX actions ordinaires du capital-actions de Nouvelle pour une considération en argent de XXXXXXXXXX $. 12.3 Nouvelle sera une «société privée sous contrôle canadien» au sens du paragraphe 125(7) de la Loi et une «société canadienne imposable» au sens du paragraphe 89(1) de la Loi. 13. ... Comme unique contrepartie, Nouvelle émettra à Gestion des actions privilégiées de catégorie A ayant une valeur de rachat égale à la JVM de la considération reçue par Gestion lors de l’émission de ces actions. ...
Ruling

1999 Ruling 9831093 - XXXXXXXXXX TAX RULING

In consideration for arranging the Primary Loans and the Secondary Loans, XXXXXXXXXX will be entitled to receive a fee (the “Loan Arrangement Fee”) from each Limited Partner, the amount of which will be equal to the fair market value of such services estimated to be approximately $XXXXXXXXXX per Unit purchased by such Limited Partner. 19. ... The XXXXXXXXXX Partnership will enter into an agreement (the “XXXXXXXXXX Services Agreement”) with the XXXXXXXXXX to provide the services and facilities necessary XXXXXXXXXX (the “XXXXXXXXXX Services”) in consideration for the XXXXXXXXXX Fee (as defined below in paragraph 26). ... In consideration for providing the XXXXXXXXXX Services, the XXXXXXXXXX Partnership will be entitled to receive a fee (the “XXXXXXXXXX Fee”) from the XXXXXXXXXX. ...
Ruling

2019 Ruling 2018-0781971R3 - Loss Consolidation

On XXXXXXXXXX, Parent subscribed for additional common shares of Lossco in consideration for cash of $XXXXXXXXXX in order to partially fund the acquisition of XXXXXXXXXX% of the issued and outstanding shares of Target. 9. ... Profitco will use the proceeds of the Loan to subscribe for XXXXXXXXXX preferred shares of Lossco (the “Preferred Shares”) in consideration for $XXXXXXXXXX. ... At no time during the implementation of the Loss Utilization Arrangement described in this letter will the Preferred Shares be: a. the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; b. the subject of a dividend rental arrangement as defined in subsection 248(1); c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration (nor will Profitco receive any other property, directly or indirectly, from an investor or any property substituted therefor) that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that would be related to Lossco (if the Act were read without reference to paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 28. ...

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