Search - consideration
Results 2461 - 2470 of 29047 for consideration
Technical Interpretation - External summary
8 May 2014 External T.I. 2014-0522771E5 - Whether a partnership has ceased to exist -- summary under Subsection 85(3)
The Partnership immediately disposed of all of its properties to a taxable Canadian corporation (the "Corporation") of which Partner B was the sole shareholder in consideration for the issuance of promissory notes and common shares (and elected under s. 85(2)) but with title to all assets staying the name of the Partnership. ...
Technical Interpretation - External summary
8 May 2014 External T.I. 2014-0522771E5 - Whether a partnership has ceased to exist -- summary under Subsection 98(1)
The Partnership immediately disposed of all of its properties to a taxable Canadian corporation (the "Corporation") of which Partner B was the sole shareholder in consideration for the issuance of promissory notes and common shares (and elected under s. 85(2)) but with title to all assets staying the name of the Partnership. ...
Technical Interpretation - Internal summary
4 March 2013 Internal T.I. 2012-0449371I7 - Downstream absorptive merger -- summary under Subsection 87(8.2)
As "Canco did receive consideration for its disposition of the shares of FA1 in the form of the FA2 shares it received," s. 87(4)(a) applied to the disposition by Canco of its FA1 shares (assuming that Canco did not elect to have s. 87(8) not apply), rather than draft para. ...
Ruling summary
2015 Ruling 2014-0563081R3 - Post-mortem pipeline -- summary under Subsection 84(2)
Proposed transactions The Trust will transfer its shares of A Co to its newly-incorporated subsidiary ("Newco") in consideration for a note equal to their combined fair market value and for a preferred share, electing under s. 85(1). ...
Conference summary
11 October 2013 APFF Roundtable, 2013-0495721C6 F - APFF 2013- Round table question 7 -- summary under Subsection 75(2)
X to Trust, at a stipulated price and for consideration equal to its FMV, does not result in the income from the Property being attributed to Mr. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Subparagraph 115(1)(a)(iii.1)
A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ...
Ruling summary
2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover -- summary under Subsection 215(6)
Pubco will transfer its shares of Canco and Forco1, and a loan owing by Forco1, to Newco mostly in consideration for interest-bearing notes of Newco- as well as the issuance of preferred shares with a nominal redemption amount and subject to a price adjustment clause. ...
Ruling summary
2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover -- summary under Subsection 52(2)
Pubco will transfer its shares of Canco and Forco1, and a loan owing by Forco1, to Newco mostly in consideration for interest-bearing notes of Newco- as well as the issuance of preferred shares with a nominal redemption amount and subject to a price adjustment clause. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Regulation 805
A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Article 6
A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ...