Search - "Contribution of Property"

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28 December 1989 Income Tax Severed Letter AC58491 - Fund Raising Activities of Charitable Organizations

The trustee is instructed to invest the contribution in property in which a trustee in Ontario is permitted to invest and to pay the net income from such investment to the donor. ...

Investments in properties and gifting arrangements

Prescribed benefits Prescribed benefits in respect of an interest in a tax shelter are defined in the Income Tax Regulations subsections 3100(1), 3100(2) and 3100(3), and include: tax credits revenue guarantees contingent liabilities limited-recourse amounts rights of exchange or conversion Representations made in connection with the property The definition of what constitutes a tax shelter depends entirely on the reasonable inferences that the CRA can draw from representations made in connection with the pro perty Representations include: written representations such as those contained in sales brochures or advertisements verbal representations such as those made in public or private information, or sales meetings Gifting arrangements Generally, a gifting arrangement is any arrangement under which it may reasonably be considered, based on statements or representations made or proposed to be made in connection with the arrangement, which a person entering into the arrangement would: make a gift to a qualified donee, or make a political contribution, of property acquired by the person under the arrangement incur a limited-recourse debt that can reasonably be considered to relate to a gift to a qualified donee or a political contribution A political contribution refers to a monetary contribution to a registered party, a registered association, or a candidate as defined in the Canada Elections Act. ...

8 May 2012 Roundtable, 2012-0435681C6 - CALU CRA Roundtable Q2

Note however, that we have previously opined that it is a question of fact as to whether a particular payment would result in a contribution to the trust for purposes of the definition of a testamentary trust in subsection 108(1) of the Act and it is our view that a contribution of property to a trust generally implies that the trust receives the property without any value being given to the contributor. ...

2004 Ruling 2004-0065921R3 - Conversion of corporations into LLCs

(b) "Share" means a membership interest in LLC 3; (c) "Stockholder" means each person signing the LLC 3 Agreement and any person who subsequently obtains a Share in LLC 3, in each case in its capacity as a Stockholder of LLC 3; (d) "Capital" of Shares is the aggregate of all amounts paid to LLC 3 and the monetary value at the time of contribution of property contributed to LLC 3 (in each case including amounts paid or contributed prior to USco 3's conversion to LLC 3) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 3 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 3 Agreement. ... (b) "Share" means a limited liability company interest in LLC 2; (c) "Stockholder" means each person signing the LLC 2 Agreement and any person who subsequently obtains Shares in LLC 2, in each case in its capacity as a Stockholder of LLC 2; (d) "Capital" of Shares is the aggregate of all amounts paid to LLC 2 and the monetary value at the time of contribution of property contributed to LLC 2 (in each case including amounts paid or contributed prior to USco 2's conversion to LLC 2) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 2 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 2 Agreement. ...

6 June 1995 GST/HST Interpretation 11635-8 - Information Concerning the Interpretation of Section 273 of the Excise Tax Act in Respect to the Assignment of a Joint Venture Interest from

., cannot purchase and dispose of property); • the participants individually or jointly carry out the transactions necessary to realize the joint venture's objectives; and • the joint venture contract, like a contract for a partnership, requires the contribution of property, credit, skill or industry, as well as the sharing of profits and losses. ...

2008 Ruling 2008-0272141R3 - Conversion of Delaware corporation into LLC

(ii) "Share" means a limited liability company interest in the LLC; (iii) "Stockholder" means each person signing the LLC Agreement and any person who subsequently obtains Shares in the LLC, in each case in its capacity as a Stockholder of the LLC; (iv) "Capital" of Shares is the aggregate of all amounts paid to the LLC and the monetary value at the time of contribution of property contributed to the LLC (in each case including amounts paid or contributed prior to D Co's conversion to an LLC) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC Agreement. ...

30 November 1995 Ruling 9625393 - DISTRESS PREFERRED SHARES

XXXXXXXXXX has personal guarantees for this indebtedness from XXXXXXXXXX. 17.XXXXXXXXXX received a loan from XXXXXXXXXX in the principal amount of approximately $XXXXXXXXXX. 18.One of the shareholders of XXXXXXXXXX provided financing in the principal amount of $XXXXXXXXXX This financing was secured by a mortgage over the property of XXXXXXXXXX The mortgage has been postponed in favour of XXXXXXXXXX No payments have been made on this debt. 19.The shareholders of the company have as a group contributed approximately $XXXXXXXXXX in personal loans and the contribution of property XXXXXXXXXX No payments have been made on these loans. 20.XXXXXXXXXX suffered losses in each of its fiscal years XXXXXXXXXX as set out XXXXXXXXXX. 21.XXXXXXXXXX has been adversely affected by the recession in that it had been unable until XXXXXXXXXX. 22.In order to more effectively compete with XXXXXXXXXX made XXXXXXXXXX expenditures totalling $XXXXXXXXXX. 23.While XXXXXXXXXX considered essential for XXXXXXXXXX the cash used XXXXXXXXXX resulted in cash-flow difficulties for XXXXXXXXXX. 24. ...

1999 Ruling 9922923 - CONVERSION OF CORPORATION INTO LLC

All the rights, privileges and powers of USco #2, and all property, real, personal and mixed, and all debts due to USco #2, as well as all other things and causes of action belonging to USco #2, shall be vested in USco LLC and shall be the property of USco LLC as they were of USco #2, and title to any real property vested by deed or otherwise in USco #2 shall not revert by reason of such conversion; b) "Share" means an LLC interest in USco LLC; c) "Stockholder" means each person signing the Operating Agreement and any person who subsequently obtains Shares in USco LLC, in its capacity as a Stockholder of USco LLC; d) "Capital" of Shares is the aggregate of all amounts paid to USco LLC and the monetary value at the time of contribution of property contributed to USco LLC in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the Operating Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the Operating Agreement. ...

15 August 2006 GST/HST Ruling 56497 - Application of the GST/HST to the affairs of XXXXX.

However, where the charity provides the person making the contribution with property or a service of more than nominal value that served as an inducement to make the contribution, then for ETA purposes, the amount of the contribution is not regarded as a gift but as consideration for the supply of the property or service given in return by the charity. ...

T3 RET, T3 Trust Income Tax and Information Return

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? ...

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