Search - consideration

L'acquisition par Holdco s'est faite pour une considération totale de XXXXXXXXXX 5. ... H)Le rachat des actions privilégiées mentionné au paragraphe 10.4 ci-dessus pour une considération égale à leur juste valeur marchande entraînera pour XXXXXXXXXX en vertu du paragraphe 84(3) de la Loi, la réalisation d'un dividende réputé égal à l'excédent de la somme payée au rachat sur le capital versé fiscal des actions rachetées. ...

XXXXXXXXXX The above figures do not take anticipated declining revenues into consideration as a result of reduced capital expenditures. ... The common shares will be issued to XXXXXXXXXX for nominal consideration. ...

Executives of XXXXXXXXXX and its subsidiaries are eligible for participation consideration, but such participation shall be limited to one performance per calender year. ... (a) To the best of your knowledge and that of XXXXXXXXXX or any of its subsidiaries none of the issues in respect of which rulings are herein requested is currently under consideration by a tax services office or taxation centre in connection with a tax return already filed and none is under objection or appeal. ...

Subject to subsections 87(3) and (3.1), the paid-up capital in respect of: (a) the Class A, B and C shares of Amalco immediately after the amalgamation will be equal to the par value of each class of shares; and (b) the membership interests in Amalco immediately after the amalgamation will be equal to the total of the amounts received by Coop #1 and Coop #2 from the members of each predecessor corporation (who became members of Amalco as a consequence of the amalgamation) as consideration for issuing the membership interests. ... Each member of Coop #1 and Coop #2 who, immediately before the amalgamation, owned any of the Class A, B or C shares of Coop #1 and a membership interest in either Coop #1 or Coop #2 as capital property and who receives no consideration other than shares of the capital stock of Amalco on the amalgamation will be deemed, subject to subsection 26(21) of the Income Tax Application Rules: (a) to have disposed of any Class A, B and C shares of Coop#1 owned by the member and the member’s membership interest in either of Coop#1 or Coop#2 pursuant to paragraph 87(4)(a) for proceeds of disposition equal to the adjusted cost base thereof to the member immediately before the amalgamation; and (b) to have acquired, pursuant to paragraph 87(4)(b) (i) the Class A shares of Amalco, if applicable, for an amount equal to the amount deemed to be the proceeds of disposition to the member of the Class A shares of Coop#1, (ii) the Class B shares of Amalco, if applicable, for an amount equal to the amount deemed to be the proceeds of disposition to the member of the Class B shares of Coop#1, (iii) the Class C shares of Amalco, if applicable, for an amount equal to the amount deemed to be the proceeds of disposition to the member of the Class C shares of Coop#1, and (iv) a membership interest in Amalco for an amount equal to the amount deemed to be the proceeds of disposition to the member of the membership interest in Coop#1 and Coop#2, whichever is applicable. ...

The Trust is resident in Canada and is a “personal trust” as defined in subsection 248(1) of the Act as none of the beneficiaries of the Trust have acquired an interest in the Trust for consideration payable to the Trust or to any other person. 4. ... The Trust will transfer the property in paragraph 4 above to Newco for consideration consisting of Newco Common Shares and promissory notes. ...

In XXXXXXXXXX, XXXXXXXXXX acquired the XXXXXXXXXX% of the Property and operating assets held by limited partnerships and, in consideration, assumed the partnerships' share of the mortgage payable, as described in paragraph 7, below, and other operating liabilities. ... XXXXXXXXXX will subscribe for a nominal amount of common shares of Newco for nominal cash consideration. ...

A l'échéance de l'entente, X devra remettre à Z la totalité de l'inventaire et ce, sans qu'aucune considération de quelque nature que ce soit ne soit reçue par X. ... Dans la présente situation, selon les renseignements que vous nous avez soumis, nous comprenons que X aurait l'obligation de livrer des biens à une date future sans considération et que la vente ou la disposition de ces biens à un montant nul s'effectuerait à l'échéance du contrat. ...

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. ... (b)(i), the XXXXXXXXXX Services Agreement will also stipulate XXXXXXXXXX In consideration for providing the XXXXXXXXXX Services, the XXXXXXXXXX Partnership will be entitled to receive a fee (the "XXXXXXXXXX Fee") from XXXXXXXXXX The XXXXXXXXXX Fee can be broken down into XXXXXXXXXX components. ...

" Instead of relying on any single test, the Court recommended the following approach: analyze the matter in terms of categories of property and types of taxation; identify the various connecting factors (i.e. factors connecting the property to a location on or off a reserve) which are potentially relevant; determine the weight to be given the connecting factors in the light of the three considerations: 1. the purpose of the exemption under the Indian Act, 2. the type of property in issue, and 3. the nature of taxation of the property. ... Consideration was also given in the case to the location where sales were made and the location where money passed between the purchaser and the vendor. ...

It is not sufficient that the Indians have "communal interests in reserve lands". b)In order to meet Guideline 4, it is not necessary that the employees work on a reserve. c)For purposes of Guideline 4, it is not necessary that the employees live on a reserve. d)It is not clear what "policy considerations" XXXXXXXXXX is referring to. e)In all of the examples set out in Guideline 4, the employer is either an Indian band which has a reserve, a tribal council representing one or more Indian bands which have reserves or an Indian organization controlled by one or more such bands or tribal councils and dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves. ... Thus, when applying the Williams case, which requires a consideration of the factors which connect an Indian's income to a reserve, the fact that a band has a reserve is considered significant. ...