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Madame, decided to avail herself of the provisions of subsection 73(1) and transfer her shares to Monsieur at their adjusted cost base, the latter would be deemed to have acquired such shares at that same adjusted cost base, regardless of the consideration actually paid. ...

23 February 2001 External T.I. 2001-0066265 F- Salaire différé français-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to the family farm was not income A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to reduce the overall cost of transferring ownership to the son or daughter who remained part of the parental estate. ...

23 February 2001 External T.I. 2001-0066265 F- Salaire différé français-- summary under Subparagraph (b)(ii) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (b)- Subparagraph (b)(ii) receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to reduce the overall cost of transferring ownership to the son or daughter who remained part of the parental estate. ...

23 February 2001 External T.I. 2001-0066265 F- Salaire différé français-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to reduce the overall cost of transferring ownership to the son or daughter who remained part of the parental estate. ...

Proposed transactions The estate will transfer its voting Class C and non-voting G preferred shares of Holdco on a s. 85(1) rollover basis to a newly-incorporated corporation (with no shareholders yet) in consideration for Class A and C shares of Newco. ...

Concurrently with 3, Trust1 will transfer its shares of Opco1 to Newco for Newco in consideration for Class C shares of Newco with full PUC, electing under s. 85(1) at the transferred shares’ stepped-up ACB. ...

However, CRA stated that there likely will be an SDA where the plan also provides that members can elect to reduce or forego future bonus entitlements and accrued vacation pay entitlements for additional allocations (of equal amounts) to the member’s account (to be paid out at the earliest of termination of employment, retirement or death) – stating that these additional features “appear to be primarily motivated by tax deferral considerations.” ...

24 January 2019 External T.I. 2016-0651291E5- Revised PHSP position- Self-insured plan-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan measuring compliance with the 90% METC-eligible expense test For insured and self-insured private health services plans (PHSPs), what are the tax consequences if not all or substantially all of the actual amounts paid under the plan are for medical expenses that are eligible for the medical expense tax credit (METC) – and do different considerations apply to a self-insured health care spending accounts (HCSA) which sets a ceiling on the amounts that can be claimed under the plan? ...

Subsequently to the transactions considered in 2017-0735771I7, ACo transferred its shares of BCo to DCo for consideration including shares of the capital stock of DCo pursuant to subsection 85.1(3) of the Act. ...

(a) After quoting Friedberg (“a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor,”), CRA indicated that where, as appeared to be the case here, the trust has no discretion as to whether to make the payment to the charity, the payment does not qualify as a gift and thus, is ineligible for the donation tax credit. ...