Search - consideration

H) Provided that XXXXXXXXXX has included or will have included an amount in respect of the undertakings related to the XXXXXXXXXX as described in paragraph 21 above, in computing its income from its business pursuant to 12(1)(a) of the Act which includes the time of the transfer of the assets described in paragraph 37 above or any preceding taxation year, the payment made by XXXXXXXXXX to XXXXXXXXXX in consideration for the assumption by XXXXXXXXXX of those undertakings, to the extent that the payment is reasonable: (i) may, pursuant to paragraph 20(24)(a) of the Act, be deducted in computing the income of XXXXXXXXXX for its fiscal period in which the payment takes place; and (ii) will, pursuant to paragraph 20(24)(b) of the Act, be deemed to be an amount described in paragraph 12(1)(a) thereof in respect of XXXXXXXXXX. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

The aggregate consideration payable by Acq. Co. for the Holdco shares under the Purchase Agreements will be identical to the consideration that the Holdcos would have been entitled to receive had they tendered the XXXXXXXXXX shares held by them directly under the Offer. 35. ...

Newco will be incorporated under the laws of the Province, being authorized to issue XXXXXXXXXX common or ordinary shares without nominal or par value, of which one (1) common share will be issued for the benefit of a Principal for which Newco will receive future consideration from the Partnership. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

In consideration for arranging the Primary Loans and the Secondary Loans, the Agent 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. ... In consideration for its services, XXXXXXXXXX will agree to pay the XXXXXXXXXX Facilitator a fee (the "XXXXXXXXXX Arrangement Fee"). ...

Le transfert du savoir de l'OSBL à une autre OSBL sous forme de licence ainsi que la considération reçue à cet égard lui fera-t-elle perdre son statut en vertu de 149(1)l)? ... Toutefois, le commandité devra prendre en considération les aspects suivants dans sa gestion courante: a) XXXXXXXXXX b) XXXXXXXXXX c) XXXXXXXXXX d) XXXXXXXXXX 33. ...

In consideration for the redeemed shares, Newco will issue a demand promissory note to Holdco (the "Newco Note") having a principal amount and a fair market value equal to the total of the redemption prices of its Class C and D special shares so redeemed. ... In consideration for the purchased/redeemed shares, Holdco will issue a demand promissory note to Newco (the "Holdco Note") having a principal amount and a fair market value equal to the total of the fair market value of the common shares so purchased and the redemption amounts of the Class A and Class B special shares. ...

As a result of the distributions of XXXXXXXXXX property to XXXXXXXXXX, on the winding-up of XXXXXXXXXX: (i) pursuant to paragraph 88(2)(b) and subsection 84(2), but subject to (ii) to (iv) herein, each of XXXXXXXXXX will be deemed to have received a dividend (“winding-up dividend A.”) on its shares of XXXXXXXXXX equal to the proportion of the amount by which the aggregate fair market value of the property of XXXXXXXXXX distributed by XXXXXXXXXX on the winding-up in consideration for the cancellation of its shares exceeds the PUC thereof that the number of shares of each class held by each of XXXXXXXXXX is of the number of cancelled shares of each class; (ii) pursuant to subparagraph 88(2)(b)(i), such portion of winding-up dividend A. as does not exceed XXXXXXXXXX CDA determined immediately before the payment of winding-up dividend A. will be deemed, for the purposes of the subsection 83(2) election referred to in paragraph 14 above, to be the full amount of a separate dividend; (iii) pursuant to subparagraph 88(2)(b)(ii), the portion of winding-up dividend A. that is equal to the lesser of: (A) XXXXXXXXXX pre-1972 capital surplus on hand as determined immediately before the payment of winding-up dividend A., and (B) the amount by which winding-up dividend A. exceeds the portion, if any, in respect of which XXXXXXXXXX will elect under subsection 83(2) will be deemed not to be a dividend; and (iv) pursuant to subparagraph 88(2)(b)(iii), winding-up dividend A., to the extent that it exceeds the portion thereof referred to in (ii) herein that is deemed to be a separate dividend and the portion referred to in (iii) herein that is deemed not to be a dividend, will be deemed to be a separate dividend that is a taxable dividend. ... As a result of the distributions of XXXXXXXXXX property to XXXXXXXXXX, on the winding-up of XXXXXXXXXX: (i) pursuant to paragraph 88(2)(b) and subsections 84(2), but subject to (ii) to (iv) herein, each of XXXXXXXXXX will be deemed to have received a dividend ("winding-up dividend B.”) on its shares of XXXXXXXXXX equal to the proportion of the amount by which the aggregate fair market value of the property of XXXXXXXXXX distributed by XXXXXXXXXX on the winding-up in consideration for the cancellation of its shares exceeds the PUC thereof that the number of shares of each class held by each of XXXXXXXXXX is of the number of cancelled shares of each class; (ii) pursuant to subparagraph 88(2)(b)(i) and subsection 89(3), such portion of winding-up dividend B. as does not exceed XXXXXXXXXX CDA determined immediately before the payment of winding-up dividend B., and in the order designated under subsection 89(3), will be deemed, for the purposes of the subsection 83(2) election referred to in paragraph 18 above, to be the full amount of a separate dividend; (iii) pursuant to subparagraph 88(2)(b)(ii), the portion of winding-up dividend B. that is equal to the lesser of: (A) XXXXXXXXXX pre-1972 capital surplus on hand as determined immediately before the payment of winding-up dividend B., and (B) the amount by which winding-up dividend B. exceeds the portion, if any, in respect of which XXXXXXXXXX will elect under subsection 83(2) will be deemed not to be a dividend and instead will be proceeds of disposition as defined by paragraph 54(i) in respect of the shares of XXXXXXXXXX; and (iv) pursuant to subparagraph 88(2)(b)(iii), winding-up dividend B., to the extent that it exceeds the portion thereof referred to in (ii) herein that is deemed to be a separate dividend and the portion referred to in (iii) herein that is deemed not to be a dividend, will be deemed to be a separate dividend that is a taxable dividend paid on each class of shares, as the case may be, in the order designated under subsection 89(3). ...

The First Nation will transfer most of its Investments Assets to the A-Trust in consideration for a non-interest bearing demand promissory grid note (Exhibit "4-C. ... The First Nation will transfer all of its Business Assets to the A-Trust, including its shares of Aco, in consideration for a non-interest bearing demand promissory grid note (Exhibit “4-D"). ...

In consideration for the transfer of the common shares of Canco1, Canco2 issued to each Holdco XXXXXXXXXX Exchangeable Shares of Canco2. ... In consideration for structuring and arranging the acquisitions and dispositions referred to herein, Purchaseco will agree to pay Broker an agency commission determined by reference to the amount of the sale proceeds received by Purchaseco from the sale of the common shares of Parentco as described below. ...

L'expression «prix de rachat» quant à chaque action privilégiée signifie le montant versé au compte de capital-actions émis et payé pour chacune avec, en plus, le cas échéant, une prime égale à la différence entre sa quote-part de la JVM au moment de son émission de tout bien reçu par la société comme considération pour ladite émission et le total formé par (1) ledit montant versé au compte de capital-actions émis et payé pour l'action et (2) sa quote-part de toute partie de telle JVM de tout bien payé par la société autrement que par l'émission d'une action privilégiées de catégorie «A». Le montant de la prime susdite sera déterminée par les administrateurs de la société sur la base de la JVM des biens reçus par la société comme considération de l'émission de ladite action et leur décision à cet égard sera finale et sans appel sauf dans le cas d'une cotisation d'impôt auquel cas les dispositions suivantes s'appliqueront. ...