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Those tax implications will include consideration of the conditions for the application of subsection 75(2). ...

Those tax implications will include consideration of the conditions for the application of subsection 75(2). ...

5 December 2012 External T.I. 2012-0445891E5- Contributed Surplus and Thin Capitalization-- summary under Subsection 18(4) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(4) IFRS not followed A non-resident corporation (NRco) transferred its shares of Canco, having a cost and paid-up capital of $100 and a fair market value of $1,000 to Newco in consideration for shares of Newco having a stated capital of $1,000, but with the paid-up capital being ground down to $100 under s. 212.1(1)(b). ...

Mr X sells all his shares of Corporation A to Corporation B in consideration for a promissory note, resulting in his receipt of a deemed dividend under s. 84.1(1)(b) that is less than the GRIP of B. ...

CRA stated: …CRA would generally not view the provision of such a guarantee as the conferral of a benefit if fair market value consideration were otherwise given in exchange for the guarantee and it would be reasonable in the circumstances to conclude that a party dealing at arm's length would provide the guarantee on the same terms. ...

[T]he individual could designate an agreed amount for the purposes of section 85 that was between the fair market value of the land and its adjusted cost base (but that would be higher than the adjusted cost base), in order to reduce the loss that was deemed to be nil and to increase the cost of the land to the acquirer as well as the cost of the consideration received by the vendor. ...

10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F- 2014 APFF Roundtable, Q. 15- Section 143.4 & Reverse Earn-out-- summary under Subsection 143.4(2) Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(2) reverse earnout obligation of Buyco re Target shares A newly formed corporation ("Newco") purchases the shares of a target corporation ("Target") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven). ...

10 August 2015 External T.I. 2015-0602751E5- Capital gains deduction and section 84.1-- summary under Paragraph 84.1(2)(a.1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1) statement of purpose and simple examples of s. 84.1 application The taxpayer and his wife acquire all the shares, qualifying as qualified small business corporation shares, of a corporation (the "Corporation") directly from XX (the "Shareholder") in consideration for a promissory note having a principal amount equal to the fair market value of the acquired shares. ...

X realized a capital gain of selling all of the common shares of HOLDCO to his children in consideration for promissory notes, but did not claim the capital gains deduction (“CGD”) under s. 110.6(2.1). ...

However, …taking into consideration the flexible tracing approach mandated… in Ludco …as well as the comments in paragraph 1.38 of the Folio …Amalco would be entitled to allocate the entire amount of the Assumed Debt to its assets other than the FA shares. ...