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First Quantum will top up the consideration paid by it for any Panamanian withholding tax that is required to be remitted. ...
14 December 2014- 8:25pm CRA confirms that a reverse earnout obligation of Buyco for Target shares continues to be an excluded obligation for debt forgiveness purposes following their amalgamation Email this Content A Buyco for a purchaser acquires the shares of a Target for consideration including a deferred purchase price (representing a "real" legal obligation), with the unpaid balance subject to reduction pursuant to a reverse earnout clause. ...
18 February 2013- 9:56am Uranium One employee stock options are to be surrendered under a privatization plan of arrangement for a deferred payment of their Black-Scholes value Email this Content An indirect Netherlands subsidiary of a Russian state company (Rosatom) is proposing to acquire the public’s 48% minority block of Uranium One shares for cash consideration of $1.3 billion under a CBCA plan of arrangement.  ...
20 December 2014- 4:32pm McKesson – Federal Court of Appeal grants amendment to McKesson appeal alleging that it was compromised by Boyle’s J’s comments thereon Email this Content Stratas JA found that, although there was no authority directly on point, the considerations respecting whether an amendment to a Notice of Appeal to the Federal Appeal could be made were similar to amendments at the trial level: is the amendment relevant to the determination of the case, would granting the amendment be prejudicial, has the appellant been dilatory and can the new ground of appeal  possibly succeed? ...
25 February 2013- 11:54am ShawCor to eliminate multiple-voting shares Email this Content ShawCor will be eliminating its current two-class share structure under a Plan of Arrangement by having a Newco purchase the ShawCor Class A shares (carrying one vote per share) on a 1-for-1  basis and the ShawCor Class B shares (carrying 10 votes per share) for consideration representing approximately a 10% premium to what's being paid for the Class A shares and comprised 90% of Newco shares and 10% cash.  ...
A requirement for this relief is that the "only consideration received in respect of" the drop-down is shares of the new foreign affiliate. ...
Michael Dolson, "Trust Residence After Garron: Provincial Considerations," Canadian Tax Journal, (2014) 62:3, 671-99 under Reg. 2601(1). ...
22 April 2013- 1:45pm CRA considers conference attendance fees to be for IPP rather than services supplies for HST purposes Email this Content CRA has indicated that where members of a national organization are charged separate fees for a conference to be held at a Canadian location, that fee will be characterized for purposes of the HST place-of-supply rules as being consideration for a supply of intangible personal property, so that the location of the conference will govern the place of supply. ...
Similar considerations arise when a taxpayer inadvertently provides privileged documents to CRA or another third party, e.g., failing to remove such documents before providing a file to a CRA auditor.  ...
An existing micro-cap TSXV-listed company will raise cash by selling its only asset and closing a private placement, and will also issue shares to the new Trust in exchange both for units of the Trust and for cash, and then will redeem out all its common shareholders (other than the Trust) in consideration for cash or the transfer to them of the Trust units.  ...

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