Search - consideration

As the sole consideration, HoldcoA will issue XXXXXXXXXX HoldcoA Common Shares to Mr. ... As the sole consideration, HoldcoB will issue XXXXXXXXXX HoldcoB Common Shares to Mr. ... The liabilities assumed as consideration for a property transferred pursuant to subsection 85(1) will not exceed the agreed amount in respect of that property. ...

On XXXXXXXXXX, Development Co acquired the remaining XXXXXXXXXX% of the common shares of the Debtor from Investco for nominal consideration when Investco, due to financial difficulties, failed to fulfill its obligations to the development and abandoned its interest in the Debtor. ... On incorporation the Debtor will acquire common shares of Newco for nominal consideration. 47. ... The cost amount, within the meaning of that term in subsection 248(1), to Newco of the Purchased Debt immediately after it is acquired from the Bank, as described in paragraph 48 of the Proposed Transactions, will be equal to the purchase price paid by Newco to the Bank in consideration for the Purchased Debt; M. ...

In consideration for agreeing to pay the indebtedness of Canco #3 XXXXXXXXXX, Canco #3 will issue a note (the "Canco #3 Note") to Canco #2 in the amount of $XXXXXXXXXX. ... In consideration for these services, the Offering Partnership shall pay to Canco #3 an expense fee of $XXXXXXXXXX (the "Offering Expense Fee"). ... Canco #3 will pay $XXXXXXXXXX (the "License Amendment Fee") to Canco #2 as consideration for Canco#2 agreeing to amend the License Agreement. ...

As consideration for the transfer of property described herein, NewCo will: (f) assume debt of DCAmalco that is allocable to the property of DCAmalco transferred to NewCo as described in (a), (b) and (c) above, all determined in accordance with paragraph 14, but not exceeding the aggregate of the agreed amounts in the joint elections under subsection 85(1) described in paragraph 15 above. ... Immediately following the transfer of property described in paragraph 16, DCAmalco will redeem from NewCo all of the DCAmalco Transferred Asset Shares for an amount equal to their FMV, being the aggregate of the DCAmalco Transferred Asset Share Redemption Amounts and will issue to NewCo in consideration therefor a demand non-interest bearing promissory note with a principal amount and FMV equal to the aggregate of the DCAmalco Transferred Asset Share Redemption Amounts (the "DCAmalco Note"). ... NewCo will redeem from DCAmalco all of its special shares for an amount equal to their FMV, being the aggregate of the NewCo Redemption Amounts, and will issue to DCAmalco in consideration therefor a demand non-interest bearing promissory note with a principal amount and FMV equal to the aggregate of the NewCo Redemption Amounts ("the NewCo Note"). ...

These opinions seem to have been based on the consideration that the market value of a note would be affected by factors other than the accrued amount of the discount (i.e. a higher profit might be realized by selling the note prior to maturity if interest rates have decreased). ... The statute in question defined "interest" as an amount payable in excess of the principal in consideration of a "loan". ... The Minister argued that part of the consideration received by the non-resident was paid "in lieu of or in satisfaction of" interest. ...

All the judges in the Wain-Town case were of the view that the taxpayer had effectively sold out' or disposed of its entire interest in the franchise in consideration of the promised payments. ... Convention defines royalties' to mean "payments of any kind received as a consideration for the use of" certain named intangible properties, it might be thought that the difficulties presented by the Saint John case would be overcome with the entering into force of the New Convention. ... In order to answer this question, it is necessary to look at the nature of the "right" here under consideration. ...

These opinions seem to have been based on the consideration that the market value of a note would be affected by factors other than the "accrued" amount of the discount (i.e. a higher profit might be realized by selling the note prior to maturity if interest rates have decreased). ... The statute in question defined "interest" as an amount payable in excess of the principal in consideration of a "loan". ... The Minister argued that part of the consideration received by the non-resident was paid "in lieu of or in satisfaction of" interest. ...

On the incorporation of TCo, Foreign Spinco subscribed for 1 common share of TCo for nominal consideration. 29. ... On the incorporation of Newco, Canco subscribed for 1 Newco Common Share for nominal consideration. ... Canco will transfer all of the Newco Common Shares to TCo in consideration for TCo Preferred Shares having an aggregate FMV at that time equal to the aggregate FMV of the Newco Common Shares so transferred to Tco. ...

The amount to be added to the stated capital account maintained for the common shares of the Newco issued as consideration for the Uco shares to D Co. will be equal to the aggregate paid-up capital attributed to such transferred shares. ... For greater certainty, the agreed amount for any capital property included in the subsection 85(1) election, referred to herein, will not be less than the amount of any liabilities assumed as consideration therefor, and will not exceed the fair market value of each such property. ... As consideration, each Subholdco will issue a non-interest-bearing demand note (the "Subholdco A Note", XXXXXXXXXX in favour of P Co., each of which will acknowledge an indebtedness in an amount equal to the aggregate Redemption Amount of its XXXXXXXXXX shares that it issued to P Co. ...

The Department explained that despite this decision, provision was not made in paragraph 20(1)(e) of the Act to allow payments made in consideration for using funds to be deducted. ... In short, the Department feels that no provision is made in paragraph 20(1)(e) to allow payments made in consideration for using borrowed funds to be deducted. ... Transactions prior to the sale which are part of the series of transactions that will include the sale, occur successively as follows: Step 1 Opco incorporates Filco Step 2 Opco disposes of a property to Filco in consideration for common shares of Filco. ...