Search - consideration

However, given CRA's interpretation of the fees as being consideration for services, they would not constitute royalties under Article XII of the Canada-US Income Tax Convention, and they would not be taxable under Art. ...

Therefore, Canco would compute its...qualifying income and qualifying losses, and its foreign non-business tax credit, without taking into consideration the...net mark-to-market loss on the Investments. ...

Therefore, Canco would compute its...qualifying income and qualifying losses, and its foreign non-business tax credit, without taking into consideration the...net mark-to-market loss on the Investments. ...

After noting that in some instances and based on Sommerer "subsection 75(2) will not apply to attribute income in respect of that property to the beneficiary," CRA stated: In the alternative, if the facts are such that it may be concluded that the trust did not acquire the shares for fair market value consideration, CRA will typically challenge the arrangement on other grounds. ...

CRA indicated that the issues in a denied ruling request, entailing the transfer of a non-Canadian business into a partnership which a non-resident became a member, could be illustrated as follows: Corp A is a taxable Canadian corporation, which transfers the business, represented by depreciable property with a capital cost and FMV of $100,000 and a UCC of $50,000, on a s. 97(2) rollover basis to a newly-formed partnership between it and its wholly-owned Canadian subsidiary (holding 1 of the 100 initial units) in consideration for a $50,000 promissory note and 50,000 units. ...

CRA indicated that the issues in a denied ruling request, entailing the transfer of a non-Canadian business into a partnership which a non-resident became a member, could be illustrated as follows: Corp A is a taxable Canadian corporation, which transfers the business, represented by depreciable property with a capital cost and FMV of $100,000 and a UCC of $50,000, on a s. 97(2) rollover basis to a newly-formed partnership between it and its wholly-owned Canadian subsidiary (holding 1 of the 100 initial units) in consideration for a $50,000 promissory note and 50,000 units. ...

On separation, a rental property was transferred between them for no consideration, and the transferee (the “Transferee”) died on August 14, 2012. 1. ...

3 June 2013 Internal T.I. 2012-0468131I7- Participating debt interest-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) deductible interest on subordinated convertible debt with participating interest payble in prefs The Canadian taxpayer issued Contracts to its wholly-owning non-resident parent ("ForParent") as consideration for its purchase from ForParent of shares. ...

Opco transfer the real estate to Realtyco in consideration for preferred shares of equal value, electing under s. 85(1). ...

Quebeco 2 transfers real property with a fair market value of $100,000 and a nominal cost amount to Quebeco 3 under s. 85(1) in consideration for $100,000 of preferred shares. ...