Search - consideration

In our opinion i) On the disposition of the loan to Subsidiary Parent will realize a capital loss on the exchange equal to the excess of the adjusted cost base of the loan over the greater of the fair market value of the loan and the fair market value of the shares received as consideration for the disposition. ii) The capital loss will be deemed to be nil pursuant to subparagraph 40(2)(g)(ii) of the Act. iii) The opening cost to Parent of the additional shares of Subsidiary will be equal to the lesser of the fair market value of the loan for which they were issued and the fair market value of the shares received. iv) The provisions of subsection 85(4) of the Act will apply to add the amount of Parent's capital loss on the disposition to the adjusted cost base of Parent's shares of Subsidiary. ...

If the proceeds received by the RRSP are less than the fair market value of the property, an amount equal to the difference between the fair market value and the consideration received by the RRSP will be taxed in the annuitant's hands. ...

The foregoing represents the Department's present understanding of the law and does not take into consideration the recent decision of the Supreme Court of Canada in the Glenn Williams case (92 DTC 6320). ...

Consideration received includes preferred shares of Newco with a PUC of $3.5 M, redeemable at $3,500,500, ACB $500. ...

We would not view it as "a logical absurdity" that subsection 55(2) should apply to a series of transactions in which a non-share property of a corporation is transferred to another corporation for share consideration which is then converted into inter-corporate dividends. ...

Requests made on behalf of specific taxpayers pursuant to paragraph 85(7.1)(b) should be directed to the relevant district office for consideration. ...

Taxpayer A would be considered to have conferred a benefit on Canco, to the extent that the fair market value of the transferred property exceeds the greater of the fair market value of the consideration received and the elected amounts determined without reference to paragraph 85(1)(e.2) of the Act. ...

Although you have not requested our comments thereon, some of the provisions of subsections 15(1), 56(2) and 245(2) may apply as a result of this type of transaction if the value of the shares received as consideration by Canco does not equal the value of the shares transferred. ...

Consideration received includes preferred shares of Newco with a PUC of $3.5 M, redeemable at $3,500,500, ACB $500. ...

Notwithstanding the above, if the requirements of paragraph 20(24) of the Act have been met, a joint election under that paragraph could be filed by the partners and the new corporation which would permit the partners to deduct a reasonable amount paid by them to the new corporation as consideration for the corporation's undertaking to provide the goods in question, and under which the amount so received by the new corporation would be brought into its income as a deemed paragraph 12(1)(a) amount received for goods not delivered before the end of the year. ...