Search - consideration

On XXXXXXXXXX, Holdco, directly and indirectly, acquired all of the capital stock of Target pursuant to a plan of arrangement in consideration for a combination of XXXXXXXXXX. ...

Therefore, since no consideration would be given by Miss M in return for the Securities and since the acquisition of these properties by Miss M would fall outside the ambit of paragraph 69(1)(c) of the Act, the cost of the Securities to Miss M following their transfer to her would be nil. ...

The Holdco Group first acquired an interest in Opco in XXXXXXXXXX in consideration for the transfer of its XXXXXXXXXX business services division to Opco. ...

The determination of the fair market value of a beneficial interest in a trust must take into consideration a number of factors. ...

Finally, the representatives also raise several policy considerations as support for their views. ...

None of the Preferred Shares 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, except as described herein. ...

The Original Agreement provided that, in consideration for the management services, Opco "shall pay to [Holdco] a management fee per annum equal to the total of (i) XXXXXXXXXX% of the net merchandise sales of [Opco], before taxes". ...

Il ne peut donc pas être pris en considération dans la situation présente. ...

None of the Lossco Preference Shares to be issued, as described in the proposed transactions, will be, at any time prior to the completion of the proposed transactions: (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); (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) held on condition that it or property substituted therefor may revert or pass to Profitco or a person to be determined by Profitco; or (e) will be issued or acquired as part of a transaction or event or series of transactions or events of the type described in subsection 112(2.5). 16. ...

20 December 2004 External T.I. 2004-0092871E5 F- Arm's Length: de facto control Unedited CRA Tags 251(1)(c) 256(5.1) 84.1 Principal Issues: Whether, in a given fact situation, subsection 84.1(1) would apply to deem a dividend to have been received by an individual who received a term note in consideration of shares of the capital stock of a "subject corporation" transferred to a "purchaser corporation"? ...