Search - consideration
Results 22991 - 23000 of 28822 for consideration
Ruling
2007 Ruling 2007-0221791R3 - Partnership Reorganization Personal Services Bus.
These calculations consider both the Partners' XXXXXXXXXX services, and may, for example, include consideration for time spent serving on the Executive Committee; and (d) the Partners receive bimonthly draws based on the anticipated profits of Partnership G. ... Pursuant to a written agreement and in consideration for a fair market value fee, Partnership G will provide the Contracting Companies with certain supplies, personnel, facilities and equipment that are required to provide XXXXXXXXXX Services. ...
Technical Interpretation - Internal
20 June 2007 Internal T.I. 2006-0178941I7 - Foreign Spin-off & Foreign Merger
The shareholders of Newco received shares of XXXXXXXXXX as consideration for their shares of Newco that they held immediately before the merger. 12. ... Legislation Where there has been an amalgamation of two or more corporations after May 6, 1974, subsection 87(4) of the Act provides that each shareholder of a predecessor corporation will be deemed by paragraph 87(4)(a) to have disposed of their shares of the predecessor corporation for proceeds of disposition equal to the adjusted cost base to that shareholder of such shares immediately before the amalgamation and will be deemed by paragraph 87(4)(b) to have acquired the shares of the new corporation formed on the amalgamation at an aggregate cost equal to those proceeds of disposition in those situations where the original shares were capital property to the shareholder and where the shareholder received no consideration, other than shares of the capital stock of the new corporation, for the disposition of the shares of a predecessor corporation. ...
Technical Interpretation - Internal
13 August 2007 Internal T.I. 2007-0228901I7 - Investment Tax Credit
This second line of authority declined to apply statutory and common law sale of goods rules but advocated a literal construction of the word "sale", such that any transfer of property manufactured by a taxpayer to a customer for a consideration, regardless of the nature of the contract between them, would amount to a sale within the meaning of the legislation. ... " In determining whether or not a contract is for the sale of goods, the point in time when ownership of the product passes to the customer is an important consideration. ...
Ruling
2007 Ruling 2007-0227521R3 - Bump - death of a shareholder
As consideration therefor, Newco will issue to the Estate a non-interest bearing demand promissory note ("Newco Demand Note"), having a fair market value and principal amount equal to the adjusted cost base of the XXXXXXXXXX Holdco Common Shares to the Estate immediately before the transfer less $XXXXXXXXXX, and XXXXXXXXXX Class A common shares of Newco ("Newco Class A Shares"). ... The aggregate amount to be added to the stated capital account maintained for the Newco Class A Shares under the BCA that are issued as consideration for the XXXXXXXXXX Holdco Common Shares will be $XXXXXXXXXX. 8.1 Immediately prior to the amalgamation of Newco and Holdco described in Paragraph 9, all money held by Holdco at that time will be used to pay down Holdco's operating line of credit with the XXXXXXXXXX, such that no money will be on hand in Holdco at the time of such amalgamation. 9. ...
Ruling
2007 Ruling 2007-0235881R3 - Class of German Arrangement & Treaty Benefits
The value of its net investments was € XXXXXXXXXX, and XXXXXXXXXX% of the Fund's investments consisted of liquid assets, which are invested so as to ensure that there is always sufficient liquidity available to fund future redemptions and to fund property acquisitions that are continually under active consideration by the Company on behalf of the Fund. b. ... Capital Requirements-A capital investment company is obliged to ensure that it meets minimum initial capital and additional fund requirements and, for this purpose, investment asset pools that are managed by the investment company are not taken into consideration. ...
Technical Interpretation - External
28 January 2008 External T.I. 2007-0250831E5 F - Part IV.1 and VI.1 Taxes - Subsection 55(2)
The Subco Preferred Shares were issued as consideration for the transfer of assets by Pubco in favour of Subco on a rollover basis. The Subco Preferred Shares are retractable for an amount equal to the fair market value ("FMV") of the consideration received by Subco upon the issuance of the shares, plus a premium to be established in function of various parameters (the "Premium"). ...
Ruling
2016 Ruling 2016-0652041R3 - Loss consolidation arrangement
Parentco will subscribe for Newco Common Shares for nominal consideration. 8. ... The Newco Preferred Shares described in Paragraph 6 will not be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; including any guarantee, covenant or agreement to purchase the Newco Preferred Shares and including the lending of funds to or the placing of amounts on deposit with, or on behalf of, Profitco or any “specified person” in relation thereto (as contemplated by subsection 112(2.2)) given to ensure that (i) any loss that Profitco or a specified person in relation thereto may sustain by reason of the ownership, holding or disposition of the Newco Preferred Shares or any other property is limited in any respect, or (ii) Profitco or a specified person in relation thereto will derive earnings by reason of the ownership, holding or disposition of the Newco Preferred Shares or any other property; (b) the subject of a dividend rental arrangement (and nor will any of the dividends paid on the Newco Preferred Shares in the course of the Proposed Transactions be received as part of a dividend rental arrangement); (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). 17. ...
Ruling
2006 Ruling 2005-0145921R3 - Innovative Instrument
There is no intention to list the XXXXXXXXXX on any public securities exchange. 14) The surrender of XXXXXXXXXX by a holder thereof to the Trust for Series XXXXXXXXXX Preferred Shares pursuant to the Holder Exchange Right, as described in 13 above, will be effected by the Trust: a) converting a corresponding principal amount of the ACO XXXXXXXXXX Note held by it into Series XXXXXXXXXX Preferred Shares in accordance with the terms thereof as set out below and b) redeeming each such XXXXXXXXXX in consideration for the transfer to the holder thereof by the Trust of the requisite number of Series XXXXXXXXXX Preferred Shares. 15) As required XXXXXXXXXX, if a XXXXXXXXXX Event occurs, each XXXXXXXXXX will automatically and mandatorily be exchanged (the "Automatic Exchange") for XXXXXXXXXX Series XXXXXXXXXX Preferred Shares. 16) The Automatic Exchange of XXXXXXXXXX for Series XXXXXXXXXX Preferred Shares as described in 15 above will be effected pursuant to the Share Exchange Agreement. ... On and after that date, ACO may, XXXXXXXXXX, redeem all or any part of the outstanding Series XXXXXXXXXX Preferred Shares upon notice by the payment of cash in an amount equal to the issue price per share plus all declared and unpaid dividends to the date fixed for redemption (the "Series XXXXXXXXXX Preferred Share Cash Redemption Price"). 28) On or after XXXXXXXXXX, ACO may at any time, XXXXXXXXXX, purchase Series XXXXXXXXXX Preferred Shares for cancellation in the open market or by tender or private contract at any price. 29) ACO may not redeem or purchase for cancellation the Series XXXXXXXXXX Preferred Shares for any consideration other than cash. 30) Holders of Series XXXXXXXXXX Preferred Shares do not have any voting rights except in certain extraordinary circumstances. ...
Ruling
2006 Ruling 2005-0126261R3 - Taxation of Indian Trust
This agreement between the parties includes commitments from the Company regarding training and education, employment and business opportunities, environmental management, social and cultural issues and financial compensation in consideration of First Nation support for the Project; (n) "Income" for the Taxation Year of the Trust shall be the income or loss of the Trust for such year computed in accordance with the provisions of the Act before the application of subsections 75(2) and 104(6) thereof for purposes of calculating income in determining the "taxable income" of the Trust; and shall, for greater certainty include taxable capital gains, net of allowable capital losses, and any notional or deemed amounts required to be included in computing the taxable income of the Trust, but shall exclude capital dividends and the non-taxable portion of capital gains; (o) "Indian Act" means the Indian Act, R.S.C. 1985, c. ... Section XXXXXXXXXX of the IBA provides that the Company shall pay to the First Nation the stipulated payments as consideration for the First Nation consenting to the Company acquiring XXXXXXXXXX rights, licences and privileges associated with the Project from the XXXXXXXXXX Government. 13. ...
Ruling
2006 Ruling 2006-0172311R3 - Appl. of s.111(5)(a)(ii) - acquisition of cont.
On XXXXXXXXXX, Parentco sold all of the issued and outstanding common shares of Lossco to Profitco for cash consideration equal to the aggregate FMV of the shares at that time. 14. ... As consideration for acquiring the Office Equipment Assets (and the interest in the associated leasing contracts) Lossco issued XXXXXXXXXX common shares and a promissory note for the balance of the purchase price. ...