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” was essentially as follows: In Year 1: Holdco1 transferred goodwill with an FMV of $500 and nominal cost amount on a rollover basis to Opco in consideration for preferred shares with a $500 redemption amount and nominal dividend entitlement; and Holdco2 subscribed a nominal amount for Opco common shares. ...

" (Full paper released on 22 December 2023) stated that, where a shareholder acquires preferred shares as consideration for the transfer of property on a tax deferred basis, the accrued gain on the property, when subsequently realized by the corporation, would be viewed as contributing to the gain on the preferred shares, and accordingly would be included in the preferred shares’ safe income. ...

12 July 2000 Internal T.I. 2000-0027857 F- PDTPE- COOPÉRATIVE-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) s. 50(1) ABIL could be claimed on members’ shares of cooperative in reliance on 12-month SBC lookback rule A workers' cooperative sold all the assets of its active business to a purchaser in consideration for preferred shares of the purchaser, with the purchaser subsequently becoming insolvent so that the shares and debt of the members in the cooperative also became worthless. ...

Development and financing Pursuant to a Development Agreement with New LP, Developer Partner will develop the property in consideration for stipulated fees and "DevCorp" will provide development administrative services to New LP for fees. ...

After generation of the requisite losses in Aco, Newco will redeem the Newco Preferred Shares of ACo in consideration for the Newco Note. ...

The unwinding of the transactions will be accomplished by: Newco redeeming the Newco Preferred Shares held by ACo in consideration for a non-interest bearing promissory note (the "Newco Note"); ACo will repaying Loan 1 by assigning the Newco Note to Lossco; and Loan 2 and the Newco Note being set-off. ...

5 October 2012 APFF Roundtable, 2012-0454061C6 F- Transfer of a Lossco to a related corporation-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) lossco with no assets or liabilities cannot be insolvent Example 1 Son claims an ABIL under s. 50(1) with respect to his share investment in a wholly-owned corporation (Lossco), which had ceased active business operations in the year, and then transfers his shares of Lossco at the beginning of the following year to a corporation wholly-owned by his Father (Profitco) for consideration of $1, with Lossco then being wound-up into Profitco under s. 88(1). ...

This hedge book was assigned to and assumed by Canco and a hedging partnership ("Canco Partnership), as a result of a novation, in consideration for the payment to Canco by FCo and certain affiliates of FCo of the "Compensation Amount". ...

Approximately XX months after 1 above, Canco3 will sell to a newly-incorporated subsidiary of Canco1 ("New ULC") the Notes B and the Canco1 Note B in consideration for a demand non-interest bearing Canadian-dollar note of New ULC (the "Note C"). ...

Immediately following the interest payment in 8, and in connection with the unwinding of the loss consolidation arrangement Newco will redeem the Newco Preferred Shares held by A Co in consideration for its issuance of a non-interest bearing promissory note (the "Newco Note"), then; A Co will repay Loan 2 by assigning the Newco Note to Lossco, then; Loan 3 and the Newco Note will be repaid by mutual set-off. ...