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During our consideration of that request, the GAAR Committee expressed its view that a Canco's acquisition of an FA's preferred shares was an avoidance transaction which would, when combined with the payment of exempt dividends thereon and the Canco's disposition of previously held common shares of the FA, result in the avoidance of subsection 93(2.01) (and 93(2) as it formerly read). ...

This requires consideration of all the circumstances, including the terms and conditions that apply in respect of the award, the duration of the program and the period for which the support is intended to be provided. ...

Generally, a plan will be considered to be a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement. ...

We have also taken into consideration that the description of the property and values were accurately described. ...

We do note that one potential difference between the facts under consideration and Rulings document 2013-051431 is that in this situation, it appears that the extension of the original contract was agreed to one day after the original contract expired. ...

Therefore, the determination in a particular situation would be based on a consideration of all the relevant facts and supporting documentation including the opinion of a qualified medical practitioner. ...

The statutory provision under consideration sets out a rule to determine a taxpayer's capital gain from the disposition of property and only expenses or outlays to be applied in reducing the gain are those incurred or made directly for the purposes of making the disposition. ...

Par ailleurs, il peut s'agir d'une véritable vente lorsqu'il est mentionné que le prix est de un dollar (1 $) et autres bonnes et valables considérations. ...

Or, à la lumière de la position de l'ARC, cet élément ne peut être pris en considération dans la détermination de la JVM pour des transactions entre personnes ayant un lien de dépendance. ...

Therefore, it must represent an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...