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Results 91 - 100 of 28811 for consideration
31 May 2016- 9:08am CRA considers that the s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Email this Content FA1 transfers all of its shares of FA2 to another non-resident subsidiary of FA1, viz., a non-share corporation (“FA3”), as a capital contribution, i.e. no new member interests are issued by FA3. ...
22 July 2016- 12:24am CRA confirms that the s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Email this Content FA1 transfers all of its shares of FA2 to another non-resident subsidiary of FA1, which is a non-share corporation (“FA3”), as a capital contribution, i.e. no new member interests are issued by FA3. ...
News of Note post
30 May 2018- 12:29am CRA finds that full compensation to a customer who returned goods precluded access to the GST/HST consideration-adjustment rule Email this Content CRA accepts that ETA s. 232 generally applies where a supplier refunds the purchase price of goods that are returned to it by its customer, so that there is no need for the customer to charge GST/HST on the refund payment. ...
News of Note post
28 March 2021- 10:29pm CRA indicates that it will only grant a request in a objection to confirm a GST/HST assessment without consideration in exceptional circumstances Email this Content ETA s. 301(4) provides "where, in a notice of objection, a person who wishes to appeal directly to the Tax Court requests the Minister not to reconsider the assessment objected to, the Minister may confirm the assessment without reconsideration.” ...
2 August 2013- 2:22pm Inter Pipeline management get rollover treatment on their $340 million consideration for agreeing to internalize management Email this Content Inter Pipeline, which is a TSX-listed LP, is being converted into a public company under an Alberta Plan of Arrangement. ...
News of Note post
16 May 2019- 1:47am Joint Committee suggests issues for consideration in drafting the new employee stock option restriction rules Email this Content The Joint Committee has provided comments on the 2019 Budget proposals to align Canada’s employee stock option rules with those in the U.S. through applying a $200,000 annual cap on employee stock option grants (based on the fair market value of the underlying shares) that may receive tax-preferred treatment for employees of large, long-established, mature firms (i.e., the s. 110(1)(d) deduction). ...
News of Note post
16 February 2022- 11:17pm The new s. 18.2 interest-limitation rules require careful consideration before their implementation Email this Content Observations on the draft s. 18.2 rules (supplemented by the elective rules in draft s. 18.21) for limiting a taxpayer’s interest and financing expenses net of its interest and financing revenues that are deductible in computing its income to a fixed ratio (ultimately 30%) of the taxpayer’s adjusted taxable income (“ATI”) (essentially, tax-basis EBITDA) include: It is unclear whether the rules apply to computing the income of a foreign affiliate, which is generally deemed by s. 95(2)(f) to be a Canadian resident for FAPI-computation purposes “except to the extent that the context otherwise requires.” ...
Public Transaction Summary
Filo/ BHP/ Lundin -- summary under Shares for Shares and Cash
Consideration for Filo shares Filo shareholders (other than those dissenting and the BHP/Lundin purchaser parties or their affiliates) will receive, as consideration for their shares, at their election: (i) $33.00 in cash for each Filo Share (the “Cash Consideration”), or (ii) 2.3578 Lundin Mining Shares for each Filo Share held (the Share Consideration), plus for each whole Lundin Mining Share issued to such shareholder, $0.0001 in cash (the “Share Consideration Cash”), or (iii) a combination of (i) and (ii) in exchange for the aggregate number of Filo Shares in respect of which such election is made. The Cash Consideration and Share Consideration are subject, in each case, to pro-ration based on a maximum cash consideration of approximately $2,767 million (the sum of the Maximum BHP Cash and the Maximum Lundin Mining Cash) and a maximum of approximately 92.1 million Lundin Mining Shares (the Maximum Share Consideration). ... All Filo shares held by BHP will be transferred to JVCo in consideration for a specified number of JVCo shares. ...
Public Transaction Summary
Brookfield Infrastructure/Enercare -- summary under Exchangeable Units
Unit Election Each Canadian Shareholder may elect: to receive from the Purchaser the Cash Consideration for each of its Common Share; or to receive from Exchange LP (A) the Unit Consideration for each of its Common Shares, or (B) the Unit Consideration per Common Share for certain of its Common Shares and the Cash Consideration per Common Share for the balance of its Common Shares (a "Unit Election").An Electing Canadian Shareholder can elect for a portion of the amount payable under the Arrangement as Cash Consideration and a portion as Unit Consideration. ... Canadian tax considerations BIP BIP is not a "SIFT partnership" as defined in s.197(1) based on the understanding that BIP is not a "Canadian resident partnership." Cash consideration A Resident that receives Cash Consideration from the Purchaser in exchange for its Common Shares under the Arrangement will realize a capital gain (or a capital loss) equal to the amount by which the aggregate cash payment exceeds (or is less than) the aggregate of the adjusted cost base to the Resident Holder of such Common Shares and any reasonable costs of disposition. ...
Public Transaction Summary
ExxonMobil/InterOil -- summary under Canadian Buyco
The consideration for each InterOil share consists of that number of ExxonMobil shares having a fixed value of U.S.$45.00 per share (or U.S.$2.3B in total), plus a cash payment of U.S.$26.87 per share (or U.S.$1.37B in total). ... Each Common Share will be transferred to AcquisitionCo in exchange for the Consideration (i.e., ExxonMobil shares and the CRP), and the payment of the CRP portion of the Consideration will be satisfied by the delivery thereof by AcquisitionCo to the Escrow Agent in accordance with the terms of the CRP Agreement. ... U.S. tax considerations The amount, timing and character of any gain, income or loss with respect to the CRP Rights are uncertain. ...