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Under the authority of its Articles of Amendment, Continuing Fund will satisfy the purchase price by issuing a series of its Class A shares (the "Merger Shares") to each of the Terminating Funds as consideration for the Terminating Fund's Assets. The number of Merger Shares of a series issued to a Terminating Fund as consideration for its Assets will be determined by dividing the Merger NAV attributed to the corresponding series of such Terminating Fund's shares by the Merger NAV per Class A share of the Continuing Fund, subject to an adjustment to account for amounts, if any, paid pursuant to the exercise of any dissent rights described in paragraph 22(d) above. ...

The Band has assigned the agreement of purchase and sale for the Property to the Limited Partnership for consideration of $XXXXXXXXXX. ... If the Canada Revenue Agency later determines that the fair market value of the contract was in excess of $XXXXXXXXXX then the amount of consideration will be adjusted accordingly. ...

As consideration, Canco pays Pubco a license fee (the "License Fee"). ... As consideration for the services provided, Canco pays Pubco a service fee (the "Service Fee"). ...

Each Terminating Fund is a Receiving Fund and, as further discussed in 22d to f below, under the authority of the Articles of Amendment as described above, Continuing Fund will issue its Class A shares (the "Merger Shares") to each Terminating Fund, as consideration for the purchase of each Terminating Fund's assets; such Merger shares will be immediately thereafter transferred and distributed to the Class A shareholders of each Terminating Fund under the Merger redemption procedure referred to in 22b above. ... As consideration for the Assets of each of the Terminating Funds, Continuing Fund will issue the Merger Shares to the Terminating Funds. ...

However, based on administrative concessions under development, consideration should be given to maintaining the partnership treatment of the entity for the relevant taxation years, as per the filings made by the taxpayers. ... In this context, considering that Delaware-LLLP disposed of all of its assets, and was subsequently dissolved, in XXXXXXXXXX, we would suggest that consideration be given to dropping the secondary position supporting the notices of reassessment issued to CanGP and CanLP on XXXXXXXXXX. ...

However, based on administrative concessions under development, consideration should be given to maintaining the partnership treatment of the entities for the relevant taxation years, as per the filings made by the taxpayers. ... In this context, we would suggest that consideration be given to allowing the Florida-LLLPs to be treated as partnerships for the purposes of the Act for the relevant taxation years, in light of the intended treatment of other taxpayer files being considered by the CRA. ...

Thereafter, the individual decides to sell his interests in the trust to a third party for a consideration of $1,000,000. ... Even if the transferor and the transferee are dealing at arm's length, CRA could reallocate the consideration between the different types of interest in accordance with section 68 of the ITA if it determines that the value that was attributed to the two types of interests is unreasonable. ...

Immédiatement après l'échange d'actions décrit ci-dessus, Fiducie FX souscrira à 100 nouvelles actions ordinaires du capital-actions de XCO, pour une considération de 100 $. 7. ... Immediately after the share exchange described above, FX Trust will subscribe to 100 new common shares of the capital stock of XCO, for a consideration of $100. 7. ...

We also considered subsection 214(15) of the Act which provides: “For the purposes of this Part, (a) where a non-resident person has entered into an agreement under the terms of which the non-resident person agrees to guarantee the repayment, in whole or in part, of the principal amount of a bond, debenture, bill, note, mortgage, hypothecary claim or similar obligation of a person resident in Canada, any amount paid or credited as consideration for the guarantee is deemed to be a payment of interest on that obligation; and (b) where a non-resident person has entered into an agreement under the terms of which the non-resident person agrees to lend money, or to make money available, to a person resident in Canada, any amount paid or credited as consideration for so agreeing to lend money or to make money available shall, if the non-resident person would be liable to tax under this Part in respect of interest payable on any obligation issued under the terms of the agreement on the date it was entered into, be deemed to be a payment of interest.” ...

As sole consideration for such transfer, Company will issue a debenture (the "Company Debenture") to Parent that will have a principal amount and FMV equal to the FMV of the Issued Newco Preferred Shares. ... ADDITIONAL INFORMATION 29) The Issued Newco Preferred Shares will not be, at any time during the implementation of the proposed transactions described herein: 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 that term is 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 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 is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 30) Each of Parent and Newco will agree with Company that Newco will be a single purpose company, will have no liabilities and will carry on no activity other than as contemplated in the Proposed Transactions. 31) Company will have the financial capacity to honor the principal amount payable under the Company Debenture. 32) XXXXXXXXXX You also advise that in your view, neither the acquisition of the Issued Newco Preferred Shares nor the related transactions XXXXXXXXXX Company's business. ...