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Acquisition and wind-up of Lossco A number of years later, Taxpayer will purchase all of the Lossco shares for nominal consideration and wind-up and dissolve Lossco (which is not expected to have any assets). ...

The Partnership subsequently transferred all of its assets, including the shares of the Creditor Affiliate, to a newly formed wholly-owned U.S. subsidiary of Partnership (the “Debtor Affiliate”), the consideration for which included the Debtor Affiliate assuming the Partnership’s liability to repay the Loan and to pay the accrued but unpaid interest thereon (the “Accrued Interest”) to the Creditor Affiliate. ...

CCRA confirmed the following consequences of the transfer of the policy by the corporation to the individual for no consideration: Pursuant to s. 148(1), the corporation was required to include $75,000 in income, being the excess of the deemed proceeds of disposition under s. 148(7) over the policy ACB ($125,000- $50,000). ...

17 December 2003 Internal T.I. 2003-0047727 F- Right of Use-Deemed Trust-- summary under Subsection 105(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(1) no s. 105(1) benefit from personal use of personal-use property of a trust An individual (“Sister”), who had been experiencing financial difficulties, disposed of her home, part of which she had been renting out, to Opco, which was a subsidiary of a corporation (“Holdco”) controlled and partly owned by her sister ("X") (with X’s children as common shareholders) for fair market value consideration. ...

It subsequently sold its Lossco shares to a profitable wholly-owned subsidiary ("Profitco") for nominal cash consideration, with Lossco then being wound-up into Profitco under s. 88(1) so that Profitco could then access Lossco's non-capital losses pursuant to s. 88(1.1). ...

27 May 2004 External T.I. 2003-0031231E5 F- Actions visées par règlement-gel successoral-- summary under Subclause 6205(2)(a)(ii)(A)(II) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2)- Paragraph 6205(2)(a)- Subparagraph 6205(2)(a)(ii)- Clause 6205(2)(a)(ii)(A)- Subclause 6205(2)(a)(ii)(A)(II) trusts in which nieces and nephews were beneficiaries nonetheless were deemed NAL for purposes of satisfying Reg. 6205(2)(a)(ii)(A)(II) Three brothers (A, B and C), who were the equal common shareholders of ABC, each effected an estate freeze in favour of a discretionary trust for the benefit of himself, his wife and their descendants, so that their common shares of ABC were converted into preferred "freeze shares and new common shares (assumed to be prescribed shares) were issued for nominal consideration to the respective family trusts (Trusts A, B and C). ...

Profit- Futures/Forwards/Hedges equity swap was to hedge the risk under a capital borrowing, so that loss on closing out the swap was on capital account In connection with its monetization of the shares of a corporation, the taxpayer transferred the shares of that corporation to a Newco ("Corporation2") in consideration for shares of Corporation2, entered into an equity swap with a financial intermediary with respect to the shares of Corporation2 under which it agreed to pay the appreciation in the value of the shares of Société2 above a ceiling level, and the counterparty agreed to pay the depreciation in value of the shares of Corporation2 below a floor level, and the taxpayer borrowed money from another financial institution. ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...