Search - consideration

The dispositions of these partnership interests were made for cash consideration only. 21. ... DC will dispose of marketable securities for consideration that consists only of cash. 33. ... The consideration received by Sibling1 will be additional common shares of the capital stock of TC1. ...

No fractional DC Special Shares will be issued and no additional consideration will be received by a Participant in lieu of a fraction of a DC Special Share. ... As consideration for the Spin-off of the Spin-off Assets to Spinco, Spinco will issue Spinco Special Shares to DC which will have an aggregate fair market value and redemption amount equal to the fair market value, at the time of the Spin-off, of the Spin-off Assets less the amount of the non-share consideration (including any liabilities assumed by Spinco and the Spinco Commitment) paid by Spinco as consideration for the Spin-off Assets, being an amount equal to the Aggregate Spinco Redemption Amount. ... To the extent that the DC Redemption Note and the Spinco Redemption Note are for different amounts, any remaining balance will be settled and extinguished for no additional consideration. ...

The agreed amount in respect of each eligible property so transferred will not be greater than the FMV of such property nor will it be less than the FMV, at the time of disposition, of the consideration therefor other than shares of the capital stock of TC1, TC2 or TC3, as the case may be, or a right to receive such shares. ... For greater certainty, the amount to be added to the stated capital account of each of TC1, TC2 and TC3 for the Class E Preferred Shares issued as partial consideration for the property transferred to it on the DC Transfer will not exceed the maximum amount that could be added to the PUC of such shares without a reduction taking place pursuant to subsection 85(2.1). ... Prior to the Proposed Transactions, DC may dispose of marketable securities, including portfolio investments, for consideration that consists only of money. 43. ...

Accordingly, the taxpayer's suggestion was referred to the Honourable James Flaherty, Minister of Finance for his consideration. ... Flaherty, Minister of Finance, for his consideration. I trust that the referral is helpful. ...

Position: Confirmed that under the present law, the payment would not qualify and referred issue to Department of Finance for their consideration. ... Flaherty, Minister of Finance, for his consideration. Thank you again for having taken the time to write. ...

Reasons: The remuneration is ascertainable and is likely received in consideration for services rendered in the office of executor. ... In our opinion, the fees you received are likely consideration for services rendered in your office as executor. ...

No non-share consideration will be paid.” Ruling B will be deleted and will be replaced with the following: “B. Section 84.1 will apply to the sale of the XXXXXXXXXX Distributor Common Shares to Transferee referred to in paragraph 36 as amended above such that the PUC of the Transferee Common Shares issued as the consideration for the sale by Shareholder 4 of the XXXXXXXXXX Distributor Common Shares will be equal to the PUC of the XXXXXXXXXX Distributor Common Shares to Shareholder 4 immediately before that sale. ...

Letter forwarded to them for their consideration. December 17, 1997 HEADQUARTERS HEADQUARTERS Trust Accounts Division M.P. ... We have advised the taxpayer that its request for confirmation of the application of an administrative position with respect to withholding taxes has been forwarded to your Division for your consideration. ...

No non-share consideration will be paid.” Ruling B will be deleted and will be replaced with the following: “B. Section 84.1 will apply to the sale of the XXXXXXXXXX Distributor Common Shares to Transferee referred to in paragraph 36 as amended above such that the PUC of the Transferee Common Shares issued as the consideration for the sale by Shareholder 4 of the XXXXXXXXXX Distributor Common Shares will be equal to the PUC of the XXXXXXXXXX Distributor Common Shares to Shareholder 4 immediately before that sale. ...

The shares issued by the corporation result from a transfer to the corporation, to which subsection 85(1) of the Act applies, of shares held by a shareholder in that same corporation in consideration for shares only of the corporation.  ... You also indicated that the aggregate PUC of the shares issued by the corporation in consideration for the transfer is equal to the PUC of the shares transferred by the shareholder. ...