Search - "Contribution of Property"

Results 1 - 10 of 111 for "Contribution of Property"

5 March 1991 External T.I. 9035565 F - Contribution of Property to Trust

5 March 1991 External T.I. 9035565 F- Contribution of Property to Trust Unedited CRA Tags 107(2.1), 108(1) testamentary trust, 248(1) personal trust Dear Sirs: This is in reply to your letter of November 29, 1990 wherein you request a technical interpretation concerning a situation where 24(1) As indicated in Information Circular 70-6R2, we do not express opinions on specific proposed transactions other than as a reply to an advance income tax ruling. ... A payment of cash to the estate to enable it to pay the liabilities will result in a contribution of property to the trust for the purpose of subparagraph 108(1)(ii) of the Act. ...

4 June 1987 Income Tax Severed Letter 5-3073 - [Request for Technical Interpretation Contribution of Property to a Partnership]

4 June 1987 Income Tax Severed Letter 5-3073- [Request for Technical Interpretation Contribution of Property to a Partnership] XXXX M. Vallée (613) 957-8982 June 4, 1987 Dear Sir: Re: Request for Technical Interpretation Contribution of Property to a Partnership This is in reply to your letter, dated March 17, 1987 whereby you request an opinion regarding a contribution of property to a partnership in the following circumstances. ...

7 April 1991 Income Tax Severed Letter - Whether contributions of property to a partnership are subject to sales tax

7 April 1991 Income Tax Severed Letter- Whether contributions of property to a partnership are subject to sales tax Unedited CRA Tags 53(1)(e)(iv) Subject: Partnership and Sales Tax A. ... In order for there to be an increase in the ACB of B's partnership interest, B would have to make a contribution of property to the partnership. ... Therefore, the payment of the liability by the partner would not be a payment of a partnership liability and would not constitute a contribution of property for the purposes of subparagraph 53(1)(e)(iv). ...

19 June 2015 STEP Roundtable

Question on the T3 guide Q 10 on the T3 Return asks: Did the trust receive any additional property by way of a contribution of property (as defined in the "Definitions" of the guide) since June 22, 2000? ... The definition “contribution of property” in the Guide reads as follows: Contribution of property – generally refers to a transfer or loan of property, other than an arm’s length transfer, to a non-resident trust including: a series of transfers or loans that results in a transfer or loan to the non-resident trust; and a transfer or loan made as a result of a transfer or loan involving the non-resident trust. ... As a preliminary observation, the definition of contribution of property in the Guide changed last year in 2014 to more accurately reflect the definition of “contribution” in s. 94(1). ...

16 December 2014 External T.I. 2014-0539841E5 F - Testamentary Trust -- summary under Testamentary Trust

After referring to s. 248(8)(a), CRA stated (TaxInterpreations translation): [A] contribution of property to a trust by a deceased contributor which takes effect at a date subsequent to death, such as a contribution of property to a trust following the death of a surviving spouse, generally would not disqualify the trust as a testamentary trust. ...

16 December 2014 External T.I. 2014-0539841E5 F - Testamentary Trust -- summary under Paragraph 248(8)(a)

Thus, a contribution of property to a trust by a deceased contributor which takes effect at a date subsequent to the deceased's death, such as a contribution of property to the trust following the death of a surviving spouse, generally would not disqualify the trust as a testamentary trust. ...

5 March 1991 T.I. (Tax Window, No. 1, p. 22, ¶1137) -- summary under Testamentary Trust

(Tax Window, No. 1, p. 22, ¶1137)-- summary under Testamentary Trust Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Testamentary Trust A payment of cash to an estate to enable it to pay its liabilities is a contribution of property, which could result in the trust losing its status as a testamentary trust and as a personal trust. ...

23 October 2009 External T.I. 2009-0309861E5 F - Tax-free Savings Accounts -- summary under Paragraph 74.5(12)(c)

23 October 2009 External T.I. 2009-0309861E5 F- Tax-free Savings Accounts-- summary under Paragraph 74.5(12)(c) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(12)- Paragraph 74.5(12)(c) s. 74.5(12)(c) inapplicable to contribution of property to TFSA of contributor’s spouse followed by spouse’s withdrawal of property and investment of proceeds Mr. ...

13 April 2015 External T.I. 2012-0449141E5 F - Usufruct -- summary under Subsection 248(3)

CRA provides a general discussion of the application of the Act to the deemed contribution of property to a trust of which the bare owner and usufructuary are the beneficiaries, and of the application of s. 107(2.1) to the winding up of the trust in connection with the termination of the usufruct. ...

26 February 2007 External T.I. 2005-0159431E5 F - Renonciation aux revenus d'une fiducie -- summary under Paragraph (c)

26 February 2007 External T.I. 2005-0159431E5 F- Renonciation aux revenus d'une fiducie-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Testamentary Trust- Paragraph (c) renunciation of income not yet realized is not a contribution to the trust CRA found that the renunciation of the income of a spouse trust by the spouse under Article 1285 of the Civil Code of Québec would not constitute a contribution of property so as to disqualify the trust as a testamentary trust given that the income was unrealized (whereas there would have been considered to be a contribution if the income was realized and, thus, payable). ...

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