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Results 411 - 420 of 28994 for consideration

Encana/Ovintiv -- summary under Outbound continuances

Second, a U.S. subsidiary of Encana (Alenco) would be distributed out of Encana in consideration for the assumption of debt and as Encana-share redemption proceeds, and Ovintiv would then drop Encana (which previously had been converted into a B.C. ... Each Encana Common Share shall be transferred to Ovintiv in exchange for (i) if the Trading Price exceeds U.S.$6.30, the issuance by Ovintiv to such Encana Shareholder of a fraction of a common share of Ovintiv and an unsecured, non-interest bearing, demand promissory note of Ovintiv with a principal amount equal to $0.25 and repayable at the option of Ovintiv by issuing a fixed number of common shares of Ovintiv (an “Ovintiv Purchase Note”), or (ii) if the Trading Price is equal to or less than U.S.$6.30, the issuance by Ovintiv to such shareholder only of Ovintiv common shares (the foregoing transactions, collectively “Share Exchange”); and as a result thereof an amount will be added to the stated capital account for the Ovintiv common shares equal to the aggregate fair market value of the consideration received by Ovintiv in exchange therefor. ...

S6-F2-C1 - Disposition of an Income Interest in a Trust -- summary under Subsection 108(7)

In such situations, subsection 108(7) provides that the person will be deemed not to have acquired their interest in the trust for consideration provided that all other beneficial interests in the trust that were acquired by way of a transfer, assignment, or other disposition of property to the trust, were acquired by persons related to that person. For example, where a husband and wife contribute property to a trust of which the husband, wife and their children are beneficiaries, their interests are deemed not to have been acquired for consideration. However, if a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...

Continental Gold/CGL Buritica -- summary under New Canadian Holdco

If all Common Shares are exchanged for Replacement Shares and no other consideration is paid for the Common Shares and certain other requirements are met, the Scheme would be a transaction described in Code section 368(a)(1)(B) (a "B reorganization"), Code section 351 (a "351 contribution"), or both. ...

Revett -- summary under Outbound continuances

"However, to the extent the Corporation owns any United States real property interests…the Corporation will recognize gain to the extent consideration received by the Corporation for such interest exceeds the Corporation's adjusted tax basis in such interest, regardless of whether the transaction qualifies as an F Reorganization or a D Reorganization. ...

OceanaGold/Romarco -- summary under Share-for-Share

OceanaGold/Romarco-- summary under Share-for-Share Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Share-for-Share S. 85.1 exchange of Romarco shares for OceanaGold shares Overview OceanaGold, which is a BC corporation based in Australia, is proposing to acquire all the shares of Romarco under a B.C. plan of Arrangement in consideration for OceanaGold shares (which in ASX trading, are represented by certificates of beneficial interest), so that s. 85.1 would apply. ...

Primero/Brigus -- summary under Shares for Shares and Nominal Cash

Brigus Pre-Spinout Reorganization Brigus will transfer various Canadian exploration properties and shares of non-resident subsidiaries to Fortune in consideration for the issuance of common shares. ...

Automotive Properties -- summary under Domestic REITs

On or before the day of Closing, the (Dilawri) Transferors will transfer their beneficial interests in the Initial Properties to the Partnership in consideration for a combination of Transferor Notes, Class B LP Units (with an equivalent number of Special Voting Units in the REIT) at the Offering Price of $10 or, in certain cases, other redeemable (Class C) partnership units in the Partnership at a price of $10.00 per such unit. ...

S4-F7-C1 - Amalgamations of Canadian Corporations -- summary under Paragraph 87(2)(o)

However, if such an option is exercised in a subsequent tax year, subsections 49(3), (3.1) and (4) generally permit the corporation to move the recognition of the consideration for granting the option from the year of the option grant to the year in which the option is exercised. Where a predecessor corporation has granted such an option and that option is exercised following an amalgamation, there is no provision in the Act which allows the consideration for granting the option to be moved from the year of grant (for the predecessor corporation) to the year of exercise (for the new corporation). … ...

H&R REIT -- summary under Releveragings

Holdco Notes held by it to the REIT for no consideration by way of a "qualifying disposition" (the “Finance Trust Disposition”). ... Holdco Notes to F17 Trust for no consideration by way of a "qualifying disposition" (the “REIT Disposition”). ... F17 Trust redemption right Pursuant to the F17 Trust Declaration of Trust, a holder of F17 Trust Units will have the right to redeem its F17 Trust Units at any time on demand in consideration for a price per unit equal to the Canadian dollar equivalent of the principal amount of Amended U.S. ...

Loblaw/GWL/Choice -- summary under Butterfly spin-offs

WFDI Amalco, WHL/TC, 2397454 (assumed in the diagram to be a holding company for Choice REIT holdings of WHL, although this is not disclosed), Rocky, Rocky Sub, WFIC Sub, Spinco and TC Amalco will amalgamate to form Spinco Amalco, with each issued and outstanding common share of WFDI Amalco being converted into one Spinco Amalco Common Share, each issued and outstanding Spinco Common Share (other than a Spinco Common Share held by a predecessor corporation) being cancelled, and in consideration therefor, GWL will issue to each such holder of Spinco Common Shares a number of GWL Common Shares per Spinco Common Share equal to the Spinco/GWL Conversion Ratio. As consideration for the issuance of GWL Common Shares, Spinco Amalco will issue 1,000,000 Spinco Amalco Preferred Shares to GWL. ...

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