Search - consideration

The Trust will: (a) convert a corresponding $XXXXXXXXXX principal amount of the ACO XXXXXXXXXX Note held by it into XXXXXXXXXX Series XXXXXXXXXX Preferred Shares in accordance with the terms thereof; and (b) redeem each XXXXXXXXXX in consideration for the transfer to the holder thereof by the Trust of XXXXXXXXXX Series XXXXXXXXXX Preferred Shares. 18. ... The consideration for a redemption or a purchase by ACO of Series XXXXXXXXXX Preferred Shares may only be paid in cash. 35. ...

The Trust will: a) Convert a corresponding $XXXXXXXXXX principal amount of the ACO XXXXXXXXXX Note held by it into XXXXXXXXXX Series XXXXXXXXXX Preferred Shares in accordance with the terms thereof; and b) Redeem each XXXXXXXXXX in consideration for the transfer to the holder thereof by the Trust of XXXXXXXXXX Series XXXXXXXXXX Preferred Shares. 16. ... The consideration for a redemption or purchase by ACO of Series XXXXXXXXXX Preferred Shares may only be paid in cash. 32. ...

These transfers will be made for no consideration from the MCT. The MCT will issue units to the Fund and their characteristics will be identical to the Trust Units. ... These transfers will be made for no consideration from the MCT. 31. After the transfers and assumption of liabilities as described above, A CT, B CT, C CT, D CT and E CT will not have any assets or liabilities and will be dissolved. 32. ...

A would first dispose of his or her Holdco common shares in favour of his or her children for FMV consideration. The children would then dispose of the Holdco common shares in favour of another corporation ("Newco") in consideration for a promissory note. ...

The only consideration such Optionholder will receive for the disposition of his/her Existing DC Options will be New DC Options. ... The only consideration such Transferred Employee will receive for the disposition of his or her Existing DC Options will be Spinco Options. ...

The amount of the dividend would reflect the tax savings resulting from the utilization of the non-capital losses of Lossco and other considerations and is estimated for the purposes of this ruling to be no more than XXXXXXXXXX% of the amount of the non-capital losses utilized in the year. ... None of the issued shares referred to herein (including the shares to be issued as described in the proposed transactions) are or will be, at any time during the implementation of the proposed transactions described herein: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject 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). 22. ...

The Option provided for consideration to be a XXXXXXXXXX% net profit royalty to the Optionors and to be exercised by carrying out exploration work of $XXXXXXXXXX and the issuance of XXXXXXXXXX common shares of the Corporation between XXXXXXXXXX. 7. On XXXXXXXXXX, the Corporation acquired an option exercisable on or before XXXXXXXXXX to purchase the Optionors XXXXXXXXXX% net profit royalty for cash consideration of $XXXXXXXXXX. ...

They would also be redeemable and retractable for an amount equal to the consideration for which the shares are issued. ... For example, the CRA is of the opinion that if, when the loan is made by Corporation A, Corporation B is unable to repay the loan and/or provide reasonable security for repayment, Corporation A would then have transferred property (cash) without having received sufficient consideration. ...

The following transactions will occur on or before XXXXXXXXXX of the year in which the loss consolidation arrangement will be unwound (the “Unwind Year”) (or such earlier date as LossCo, NewCo and NewLossCo may have agreed upon): (a) NewCo will redeem the NewCo Preferred Shares held by NewLossCo in consideration for a non-interest bearing promissory note issued by NewCo (the “NewCo Note”); (b) The NewCo Note will have a principal amount and fair market value equal to the redemption amount and fair market value of the NewCo Preferred Shares redeemed; (c) NewLossCo will repay Loan 1 by assigning the NewCo Note to LossCo in full satisfaction of the amount due under Loan 1. ... The NewLossCo Common Shares and the NewCo Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be: (a) the subject of any undertaking that is a guarantee agreement as contemplated in subsection 112(2.2); (b) the subject of a dividend rental arrangement as contemplated in subsection 112(2.3); (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 39. ...

COMMENTS Nothing in this advance income tax ruling should be construed as implying that we are ruling on any tax consequences relating to the Facts and Proposed Transactions described herein other than those specifically described in the ruling given above or, without limiting the generality of the foregoing, any issues concerning the validity or existence of the Partnerships or any issues or considerations arising from the LP Agreements, including allocation of income, gains or losses of the Partnerships and the application of section 103; any withholding tax considerations as may be relevant for the purposes of the Proposed Transactions; and the GST implications of any of the Proposed Transactions. ...