Search - consideration
Results 24381 - 24390 of 29067 for consideration
Ruling
2009 Ruling 2008-0297571R3 - Loss
None of the issued shares referred to herein are or will be, at any time during the implementation 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); 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) held on condition that it or property substituted therefore may revert or pass to Profitco or a person to be determined by Profitco. 35. ...
Ruling
2009 Ruling 2009-0338281R3 - Partnership Reorg-Personal Service Business
Provided the amount of the Partnership's income allocated to the Named Partner is otherwise reasonable having regard to all of the relevant circumstances, the Named Partner's share of the Partnership income will not be altered pursuant to subsection 103(1) of the Act solely as a result of the Named Partner choosing, pursuant to the proposed transactions, to provide all of its Professional Services to the Partnership through the Particular Contracting Company in consideration for the Fees. ...
Ruling
2008 Ruling 2008-0282491R3 - XXXXXXXXXX Claim Trust; 149(1)(c)
In consideration of the Total Amount paid by Canada to the First Nation and the fulfillment of other promises made by Canada in the Settlement Agreement, the First Nation will forever release and discharge Canada and any of its Ministers, officials, servants, employees, agents, successors and assigns from any action, cause of action, suit, claim or demand whatsoever, whether in law, in equity or otherwise, which the First Nation and the past, present and future Members of the First Nation and any of their respective heirs, descendants, legal representatives, successors and assigns may ever have had, may now have or may in the future have against Canada and any of its Ministers, officials, servants, employees, agents, successors and assigns with respect to, among other things, the XXXXXXXXXX Claim and the XXXXXXXXXX Issue, as more fully set out in Article XXXXXXXXXX of the Settlement Agreement. 19. ...
Ruling
2007 Ruling 2006-0198101R3 - Partnership Reorganization Professional Corp.
XXXXXXXXXX was admitted to the Partnership in XXXXXXXXXX as a special member in consideration for the contribution by XXXXXXXXXX to the Partnership of certain equipment used by the Partnership in carrying on the Practice. ...
Ruling
2007 Ruling 2006-0201361R3 - Sale - Leaseback Arrangement
On XXXXXXXXXX, the Province responded to this request and indicated that, subject to certain due diligence requirements and Subco's consideration of certain additional issues, the Province was prepared to forward Subco's request to Cabinet. 25. ...
Technical Interpretation - External
20 April 2005 External T.I. 2005-0113961E5 F - Avocats nommés à la magistrature
If the vendor and purchaser jointly elect to have the provisions of subsection 22(1) apply: the vendor may deduct, in computing income, the amount by which the face value of certain of the vendor's accounts receivable exceeds the consideration received for them; and the purchaser includes the excess in income but will be deemed to have included the accounts receivable in income so that the purchaser may subsequently deduct certain amounts in respect of doubtful accounts and bad debts. ...
Ruling
2005 Ruling 2005-0151751R3 - interest deductibility; XXXXXXXXXX
In consideration for the release of its obligations under the Existing Service Agreement XXXXXXXXXX, ForeignCo #2 will pay to XXXXXXXXXX amounts XXXXXXXXXX. ...
Ruling
30 November 1996 Ruling 9704843 F - VENTE D'ACTIONS, REORGANISATION
Le capital action émis et en circulation de Acquisitionco sera constitué de XXXXXXXXXX actions ordinaires émises pour une considération totale de XXXXXXXXXX $. ...
Ruling
30 November 1996 Ruling 9722883 - BUTTERFLY REORGANIZATION
In consideration for such transfer Newco will assume liabilities of Distributorco and will issue to Distributorco Newco Preferred Shares, having an aggregate redemption and retraction amount and fair market value equal to the amount by which the fair market value of the transferred properties that will be received by Newco exceeds the fair market value of the liabilities assumed by Newco. ...
Technical Interpretation - Internal
10 March 1998 Internal T.I. 9724307 - MEMBER SHARE CAPITAL
As noted in our previous memorandum, we stated that the deemed allotment of shares (under subsection 20(6) of the CU Act) did not actually require that any shares actually be issued by the credit union, nor did we agree that a member must knowingly enter into a contract to purchase such shares and the credit union must knowingly accept the consideration offered for such shares as payment on account of, or in respect of shares. ...