Search - consideration

The estate will transfer, to a “Newco” formed by it under the CBCA, Class A preferred shares of Holdco in consideration for a demand note ("Note 2") of Newco and a Class A share of Newco (apparently, its only issued and outstanding share), electing under s. 85(1). ...

Fco makes a PUC distribution to the trust by distributing a note of a subsidiary in an amount sufficient for the trust to pay the tax on the above taxable dividend. the father of CC4 settles a new trust for the exclusive benefit of CC4, with the old trust transferring its Class Z shares of Fco to the new trust for no consideration, and with the new trust not electing out of the application of para. ...

Proposed transactions The estate will transfer to a corporation newly incorporated by it (Newco) its Class A and Class B shares of Holdco in consideration for Note 1 (plus some Newco Class A voting and participating shares) and Note 2 (plus some Newco Class B voting redeemable preferred shares), respectively, electing under s. 85(1). ...

However, the Directorate indicated that “to allow a taxpayer who has made a misrepresentation to use subparagraph 152(4)(a)(i) to reduce the amount of tax assessed would be inappropriate,” in light of various considerations. ...

Pursuant to a new services agreement with Foreignco, Canco will provide “Computer Services” and “Other Support Services” to Foreignco and other non-resident members of the group in consideration for reasonable fees. ...

The Directorate also stated: Consideration was given to whether paragraph 8 of Article 10 of the Treaty could apply only to dividends paid on a particular tranche of shares (i.e. the initial acquisition of shares or a subsequent acquisition of shares resulting in 10% beneficial ownership, either directly or indirectly). ...

7 May 2024 CALU Roundtable Q. 5, 2024-1007081C6- Gift of life insurance policy-- summary under Subsection 248(35) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(35) illustrations of the application of ss. 248(35) and (36) to gifts of life insurance policies S. 248(5) would apply where: Within 2 years of the s. 98(5) wind-up of a partnership that had held a policy on the life of the sole proprietor (A) for over 10 years, A donated the policy to a registered charity (a “donation”) (CRA indicated that the period of holding by the partnership would not count for s. 248(25) purposes); An individual transfers a newly-acquired policy for nil consideration to a wholly-owned corporation and, 35 months later, the corporation gifts the policy to a registered charity; A parent purchased a policy on the life of the parent’s 8-year old child and then gifted it to the child on attaining 21, with the child then making a donation within 3 years (s. 248(36) did not apply since the policy had been held by the parent for over 10 years); and A transfers a policy on A’s life that A had held for 15 years to A’s spouse (B) on a s. 146(8.1) rollover basis, and B makes the donation within 3 years thereafter (again s. 248(36) would not apply, and B’s gain under s. 148(7) would be attributed to A). ...

Numberco will redeem its preferred shares in consideration for assigning the non-interest-bearing note to Profitco, which will then be set-off against the IB Note. ...

Following the realization by Trust 1 of gain pursuant to s. 104(4)(b)(ii) on the subject shares, it will dispose of the Subject Shares to Holdco 1 in consideration for Notes 1, 2 and 3 of Holdco 1. ...

Regarding what was a housing unit [“logement”], with the questioner referring, as examples for consideration, a seniors’ residence, or business premises with a fully-equipped kitchen where dinner was served to the staff, CRA noted that these proposals were introduced as part of legislation “to make life more affordable and build an economy that works for everyone” and stated that “[i]n such a context, the CRA is prepared to interpret the expression ‘housing unit’ with some flexibility” but then stated: That said, with respect to your specific questions, they are currently under review and will be the subject of consultations with representatives of the Department of Finance in order to provide you with further clarification on the scope of this term. ...