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Results 291 - 300 of 28976 for consideration
Technical Interpretation - External
19 December 1991 External T.I. 9126915 F - Attribution of Gain to Transferor where Nil Consideration
19 December 1991 External T.I. 9126915 F- Attribution of Gain to Transferor where Nil Consideration Unedited CRA Tags 74.2(1), 74(2), 73(1) 912691 Dear:19(1) Re: Application of Subsection 74.2(1) of the Income Tax Act (the Act} We are writing in reply to your letter of August 19, 1991, wherein you requested that we confirm your views on the interpretation of subsection 74.2(1) of the Act as it relates to the following situation. ...
Miscellaneous severed letter
7 October 1990 Income Tax Severed Letter - Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property
7 October 1990 Income Tax Severed Letter- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21)(d.1) Dear Sirs: Re: XXX "Timber Quota Certificate"/"Timber Licence") Paragraph 13(21)(d.1) of the Income Tax Act (the "Act") We are writing in reply to your letter of September 11, 1990, in which you request our interpretation of whether a "Timber Quota Certificate" and a "Timber License" constitute a timber resource property as defined in paragraph 13(21)(d.1) of the Act. ...
Technical Interpretation - Internal
21 June 1994 Internal T.I. 9408087 - TIMING CONSIDERATION TO A HOME RELOCATION LOAN
21 June 1994 Internal T.I. 9408087- TIMING CONSIDERATION TO A HOME RELOCATION LOAN Unedited CRA Tags 110(1)(j) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Technical Interpretation - External
24 October 1990 External T.I. 9024635 F - Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property
24 October 1990 External T.I. 9024635 F- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21) timber resource property 24(1) 5-902463 C.K. ...
Public Transaction Summary
Killam -- summary under Domestic REITs
Convertible debentures of Killam (bearing interest of around 5.5%) will be assumed by the REIT in consideration for the issuance of a note to it by Killam. ... Each remaining Common Share will be deemed to be transferred to the REIT in consideration for one REIT Unit. ... Each Common Share held by the REIT will be transferred to the Limited Partnership in consideration for Class A LP Units valued at $1.00 per unit. ...
Public Transaction Summary
AIP/Canam -- summary under Canadian Buyco
AIP/Canam-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco AIP acquisition of Canam accommodated non-cash dividends to or rollovers by the key shareholders Overview The acquisition of Canam by the Purchaser (a subsidiary of AIP) occurred for cash consideration of $12.30 per share (the “Consideration”- implying a total enterprise value including debt of $875M), subject to two exceptions. ... The Holdco shareholders then sold their Holdco shares as part of the Quebec Plan of Arrangement for cash consideration (corresponding to the transaction value of the underlying Canam shares) except as described below. Second, members of the same 27% group could timely elect to transfer their Canam or Holdco shares to the Purchaser for Purchaser shares with a value agreed to correspond to the cash consideration. ...
Public Transaction Summary
Cominar/Canmarc -- summary under Trust Acquisitions of Trusts
Cominar/Canmarc-- summary under Trust Acquisitions of Trusts Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- Trust Acquisitions of Trusts Cominar offer for Canmarc Overview Cominar REIT through 10 Newco subsidiaries is offering cash or (at the Canmarc unitholder's option) Cominar units for Canmarc units, subject to the total number of Cominar units being capped at 16M but with no potential proration of the cash consideration. ... Offer Cominar Acquisition Group offers to purchase solidarily (jointly and severally) all of the issued and outstanding Canmarc Units which Cominar does not directly or indirectly own, together with the associated unitholder rights plan (URP") rights including all Canmarc Units issued upon the conversion, exchange or exercise of the convertible securities for a consideration per Canmarc Unit, at the option of the Unitholder, of $15.30 cash or 0.7054 Cominar Units. ... Subsequent acquisition transaction A subsequent acquisition transaction in respect of Canmarc may take the form of one or more amendments to the declaration of trust of Canmarc to provide for the acquisition and/or exchange and/or redemption of all outstanding Canmarc Units (other than those held by Cominar and the Cominar Acquisition Group), in either case for a price equal to, and payable in the same form as (including consideration elections, deemed consideration elections and pro-rationing), the consideration paid for Canmarc Units acquired under the Offer. ...
Public Transaction Summary
Anderson/Freehold -- summary under Taxable spin-offs
Each Anderson option will be cancelled in consideration for one New Anderson option. Anderson will be deemed to have transferred its assets (other than certain non-core assets being predominantly shallow gas assets) to New Anderson for fair market value consideration consisting of the assumption of liabilities (including Anderson debentures) and the issuance of New Anderson common shares. ... New Anderson shall transfer its Anderson common shares to Freehold in consideration for cash consideration (subject to an escrow amount) of $35 million. ...
Public Transaction Summary
Plazacorp/KEYreit -- summary under Trust Acquisitions by Corporations
The consideration is a combination of cash and Plazacorp shares (with the ability to make an s 85 election), with such consideration being at the election of the KEYreit unitholder but with the overall cash and share proportions fixed at 50-50. The consideration (valued at $8.35 per KEYreit unit) represents a 35% premium over the closing price when the rival Huntingdon offer was announced. ... Offer Plazacorp is offering to purchase each outstanding KEYreit (incluidng those resulting from conversion of debentures or other securities) for $8.35 per unit in cash 1.7041 Plazacorp shares, or any combination thereof provided that the aggregate cash consideration is limited to $62.15M and the maximum share consideration is limited to the equivalent of ½ the outstanding KEYreit units (after giving effect to debenture conversions). ...
Public Transaction Summary
Newmont/Goldcorp -- summary under Direct Target Acquisition
Overview Newmont is proposing to acquire all the shares of Goldcorp pursuant to an Ontario Plan of Arrangement for consideration consisting of 0.3280 of a Newmont Share and US$0.02 in cash for each Goldcorp Share. ... Canadian tax consequences A Resident Holder (other than a Resident Dissenter) who disposes of Goldcorp Shares to Newmont under the Arrangement will be considered to have disposed of each Goldcorp Share for proceeds of disposition equal to the sum of the Cash Consideration and the aggregate fair market value at the Effective Time of the Consideration. ... Holder’s exchange of Goldcorp Shares for the Consideration pursuant to the Arrangement will be a taxable transaction for U.S. federal income tax purposes. ...