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The Lossco Series III Preferred Shares will not at any time during the implementation of the Proposed Transactions be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as 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). 33. ...

31 July 2012 External T.I. 2012-0449871E5 F- Attribution rules- transfer to corporation Unedited CRA Tags 74.4(2); 74.4(3) Principales Questions: In a situation where the purpose test set out in subsection 74.4(2) is met with respect to a transfer of property by X, how would be computed the amount to be included in X's income by virtue of subsection 74.4(2) after the transfer of the excluded consideration received by X from the corporation in favour of another corporation controlled by X? ...

With respect to Scenario 4, we assume that the redemption value of the preferred shares of Divco is equal to the fair market value of the consideration received by Divco upon the issuance of the shares. ...

The Newco Preferred Shares which will be issued as described in 15 above, will not be, at any time during the implementation of the Proposed Transactions: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as 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: A. 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 B. any right of the type described in subparagraph 112(2.4)(b)(ii). 25. ...

We were not advised of any other activity that would require our consideration. ...

The expenses incurred would be part of the consideration given for any right acquired by the purchaser with respect to the claims. 2. ...

undivided interest in the Property to Child3 in trust for a consideration of $XXXXXXXXXX. ...

Plusieurs facteurs économiques et financiers doivent être pris en considération. ...

B half of her OPCO preferred shares for no consideration. This transfer is made on a tax-deferred basis pursuant to subsection 73(1). ...

The amount of interest that is required to be paid for the purposes of subsection 161(2) is determined in accordance with subsection 161(4.1) that provides in part as follows:... where a corporation is required to pay a part or instalment of tax for a taxation year computed by reference to a method described in subsection 157(1), the corporation is deemed to have been liable to pay on or before each day on or before which subparagraph 157(1)(a)(i), (ii) or (iii) requires a part or instalment to be made equal to the amount, if any, by which (a) the part or instalment due on that day computed in accordance with whichever allowable method in the circumstances gives rise to the least total amount of such parts or instalments of tax for the year, computed by reference to (i) the total of the taxes payable under this Part and Parts VI, VI.1 and XIII.1 by the corporation for the year, determined before taking into consideration the specified future tax consequences for the year, (ii) its first instalment base for the year, or (iii) its second instalment base and its first instalment base for the year, Please note that pursuant to subparagraph 161(4.1)(a)(i), interest is assessed based on the total of the taxes payable for the year and not based on the estimated taxes used for the purposes of subparagraph 157(1)(a)(i) of the Act. ...