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(b) Subsection 84(1) On a transfer of property to a Canadian corporation in consideration for shares, which may in many cases be subject to an election under subsection 85(1), a deemed dividend will arise under subsection 84(1) if the paid-up capital of the shares thereby issued exceeds the fair market value of the property acquired by the corporation. ... (d) Assets on income account It is understood that Revenue Canada may now regard certain shares received by a transferor as consideration for a transfer of assets in respect of which a section 85 election is filed, to be assets on income account. ...

Given such incentive legislation, the Court concluded that a transaction that clearly falls within such object and spirit cannot be said to reduce income unduly or artificially merely because the taxpayer was influenced by tax considerations. ... While in our view, subsection 55(1) and 245(1) are not applicable in the situation at hand, you may wish to give consideration as too whether or not the properties acquired by the taxpayer meet the definition of replacement property in subsection 44(5) of the Act. ...

As paragraph 81(l)(h) of the Act has been recently enacted into law (Bill C-18), XXX representative have requested consideration of whether the payments received by the XXX in partnership from the Corporation are exempt under this provision. ... A further consideration is that paragraph 81(1)(h) refers to a "social assistance payment... made on the basis of a means, needs or income test to the extent that it was received directly or indirectly by the taxpayer for the benefit of another". ...

In somewhat similar circumstances to the 2021 technical interpretations mentioned above, the CRA was asked about issuing discretionary dividend shares for nominal consideration. ... Response Given the broad scope of these provisions, whether any of subsections 15(1), 56(2) or 246(1) of the Act apply in respect of a particular tax planning arrangement (including those that involve life insurance policies and/or life insurance shares) can only be ascertained, on a case-by-case basis, after a comprehensive review and analysis of the relevant facts and agreements amongst the parties (including any valuation considerations, as applicable), as well as the objective of the tax planning and the intent of the parties (express or implied) in respect of the arrangement. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ... While each case is found to turn upon its own facts, and no infallible criterion emerges, nevertheless the decisions are useful as illustrations and as affording indications of the kind of considerations which may relevantly be borne in mind in approaching the problem. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Accordingly, consideration could be given to deleting the reference here to class 12. ... Could consideration be given to choosing some consistent terminology so as not to confuse a reader? ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...