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Finance Trust will transfer all of the US Holdco Notes held by it (being most of its property) to the REIT for no consideration (the “Disposition”). ...

However, as the governing legislation did not permit Canco to invest in Foreignco shares, the sums agreed by Canco were agreed, as an informal contractual matter, to be the consideration for “special warrants” to acquire shares of Foreignco, with such warrants being redeemable by the holder for the FMV of the corresponding Foreignco equity. ...

For the purposes of Part XIII and s. 116, any amount paid or credited by a payer to the sub-custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

. … However, the bonus contribution and vacation pay contribution components of the Supplemental Plan, as well as the Retirement Allowance Plan, appear to be primarily motivated by tax deferral considerations …[and] would most likely constitute an SDA. ...

Newco will acquire the shares of Holdco for cash consideration funded as described in above, for a note and for Class B non-voting redeemable retractable preferred shares of Holdco (whose paid-up capital is limited in accordance with s. 84.1(1)(a)), with a s. 85(1) election being made. ...

CRA responded: Question 1 – Broad class of persons The phrase “a broad class of persons” … would generally encompass a large group of persons dealing with a financial institution at arm’s length who have been offered the same incentive without regard to tax considerations or their other personal or financial circumstances. … For example, an incentive offered by a financial institution to all clients who invest or maintain registered and non-registered accounts at a specific minimum dollar amount would generally be considered to be offered to a broad class of persons. … [W]hether an incentive offered only to a “select group” of clients would qualify for the exception would depend on the size of the group relative to the financial institution’s client base as a whole as well as on the particular criteria used to select eligible investors. ...

In connection with unwinding the loss consolidation arrangement, Newco will redeem the Newco Preferred Shares held by NewLossco in consideration for a non-interest bearing promissory note (the “Newco Note”), with NewLossco repaying the IB Loan by assigning the Newco Note to Lossco, and with Newco and Lossco will agree to set off the amount due under the NIB Loan against the amount due under the Newco Note. ...

In some instances, a note was issued by the corporation to the estate as consideration for the redemption of a portion of its shares held by the estate; and some of the proposed transactions contemplated the corporation liquidating some of its assets in order to repay this note before the Pipeline Note is repaid. ...

The designations made under subsection 104(21.2) by Trust 1 in respect of each of Trust 2 and Trust 3 must be taken into consideration in order to determine the eligible taxable capital gains of Trust 2 and Trust 3, respectively. ...

UScorp2 will sell all of the shares of USco1 to Foreignco2 (so as to avoid split ownership of Amalco) for fair market value consideration. ...