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. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

21 November 2001 External T.I. 2000-0062895 F- BOURSE D'ETUDES OU REVENU D'EMPLOI-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee – but could be non-taxable as primarily for employer’s benefit A professional services firm recruits university students and offers them a sum of money to cover the cost of their studies. ...

In this regard, the Directorate noted that, by virtue of s. 118(5), in order to claim the wholly dependent person credit in respect of the second child, no amount of child support could have been paid in respect of that child – and noted that “[i]n order for subsection 118(5) to apply, the support payments do not have to be deductible.” ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved The shareholders of a Canadian-controlled private corporation (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price in one year’s time as compared to the portion of the sale price allocated to such shares. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 85(1)(f) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...

10 January 2002 External T.I. 2001-0112885 F- ASSURANCE-VIE ET PRET REMBOURSE AU DECES-- summary under Subsection 207.6(2) Summary Under Tax Topics- Income Tax Act- Section 207.6- Subsection 207.6(2) overview of employer use of life insurance policy to fund RCA benefits CCRA provided the following overview of the use of a life insurance policy to fund an RCA: [W]here an employer acquires an interest in a life insurance policy to enable it to fund benefits to be received by a person on or after a taxpayer's retirement … [t]he provisions of Part XI.3 then apply. ...

“[I]t is not necessary for the purposes of subparagraph 122.3(1)(b)(i) that this contract be with the person who undertakes the qualifying activities or that the qualifying activities be undertaken directly by the specified employer under this contract, as long as the services provided by the specified employer under the contract to which it is a party are related to a contract entered into by another party with respect to those qualifying activities ….” ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition damages received for use of a property contrary to the recipient’s co-ownership right were tax-free receipts After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieur obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...