Search - consideration
Results 23421 - 23430 of 29026 for consideration
Technical Interpretation - External
7 September 2016 External T.I. 2014-0563781E5 - Articles 10 and 11 of Canada-UK Treaty
We generally agree with your reasoning, however as we mentioned earlier, a determination of whether unrelated persons are dealing with each other at arm’s length can only be made after the consideration of all the relevant facts and circumstances. ...
Technical Interpretation - Internal
9 August 2016 Internal T.I. 2014-0526171I7 - Resettlement of a Trust
In consideration of a purchase price of CDN $XXXXXXXXXX, Inc acquired among other things the following: 8. ...
Ruling
2009 Ruling 2008-0280391R3 - Loss Consolidation
The Newco Preferred Shares and Parent Preferred Shares will not be, at any time during the implementation of the Proposed Transactions described herein: (a) the subject of any undertaking that is referred to in subsection 112(2.2) of as a "guarantee agreement"; (b) the subject of a dividend rental arrangement as that term is defined in subsection 248(1); (c) the subject of any secured undertaking of the type of 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). 21. ...
Technical Interpretation - Internal
6 April 2009 Internal T.I. 2008-0289281I7 - loss Utilization - Minority Interest
As consideration, Subsidiary assigned to Ultimate Parent the promissory note from UPSub. 11. ...
Ruling
2009 Ruling 2009-0320211R3 - Substituted Property
On XXXXXXXXXX, Parent made an offer to purchase all the issued and outstanding common shares of the capital stock of Target for $XXXXXXXXXX per common share by way of a take-over bid, for a total cash consideration of approximately $XXXXXXXXXX. 10. ...
Technical Interpretation - External
28 August 2009 External T.I. 2009-0325881E5 F - Application of Subsection 89(8)
The application of subsection 89(8), without taking into consideration variable C of such provision, would result in an LRIP addition of $XXXXXXXXXX at Target level. ...
Ruling
2009 Ruling 2009-0316961R3 - Donation of flow-through shares
The price payable by the Liquidity Providers will be $XXXXXXXXXX per Share. 24) ACO, on behalf of the Liquidity Providers, and the Corporation, on behalf of the Charities, negotiated this price of $XXXXXXXXXX per Share at arm's length, without any direction or influence from the Donors or the Resource Company. 25) As consideration for having arranged the series of transactions, the Charities will pay a fee to the Corporation equal to XXXXXXXXXX % of the gross selling price of any Shares sold to the Liquidity Providers. 26) You advise that no fees, commissions or compensation of any kind will be paid by or received by any participants in the proposed transactions other than those described in 12, 22 and 25 above. 27) You advise that all purchases, transfers and dispositions of the Shares will comply with all applicable securities laws. 28) Other than the tax benefits relating to the CEE, the investment tax credit and the focused flow-through share tax credit, you advise that the Donors will not receive any benefit or advantage in respect of the donation of the Shares to the Charities. ...
Ruling
2009 Ruling 2009-0312611R3 - Loss Consolidation
Furthermore the consideration for which any of the shares are issued will not include an obligation of an unrelated investor to make payments, any portion of which would be required to be included in computing the income of the issuer nor will it include any right to receive payments or property that may revert to the investor. 11. ...
Conference
24 November 2009 CTF Roundtable Q. 7, 2009-0347251C6 - Exchangeable Debentures - 20(1)(f)
Response 3: We are still of the view that when a holder of an exchangeable debenture exercises the right to exchange the debenture for the target shares, the holder would dispose of the debenture for proceeds equal to the fair market value of the consideration received, i.e. the fair market value of the target shares. ...
Ruling
2009 Ruling 2009-0336261R3 - transferable warrants & flow through shares
.; d) "consideration" for the purposes of the definition of "flow-through share" in subsection 66(15) shall be the exercise price of $XXXXXXXXXX per common share paid to the Corporation upon exercise of the Series B Warrant as described in paragraph 5(ii) below; e) "mineral resource" has the meaning assigned under subsection 248(1); f) "flow-through share" has the meaning assigned under subsection 66(15); g) "public corporation" has the meaning assigned under subsection 89(1); h) "prescribed share" means a share of the capital stock of a corporation which is a prescribed share pursuant to section 6202.1 of the Regulations for purposes of the definition of flow-through share in subsection 66(15); i) "prescribed Canadian exploration and development overhead expense" has the meaning assigned under subsection 1206(4.2) of the Regulations; j) "principal-business corporation" has the meaning assigned under subsection 66(15); k) "taxable Canadian corporation" has the meaning assigned under subsection 89(1); and l) XXXXXXXXXX Our understanding of the facts, proposed transactions and the purposes of the proposed transactions is as follows: Facts 1. ...