Search - consideration

For Part 2, in the situation where Amalco transfers the property to another corporation in exchange for consideration that includes shares and makes the s. 85(1) election, the answer comes in two parts because it depends on the agreed amount. ... As part of the spin-out, Holdco transferred shares of Opco with an ACB of nil and a FMV of $1,000 to Newco in consideration for shares of Newco with an ACB and paid-up capital (“PUC") of nil and a FMV of $1,000. Opco then transferred Asset 2 to Newco in consideration for shares of Newco with an ACB, PUC and FMV of $1,000. ...

CanCo would be required to collect tax on the total consideration for the single supply of the call centre service. 3. ... CRA Comments We have given further consideration to this issue and the information you have provided. ... We will bring this issue and situation to the attention of the Department of Finance for tax policy consideration. ...

Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...

CRA found this tax to be an “income or profits tax” Can the CRA provide any comments on its consideration of what constitutes an “income or profits tax”? ... Foreign Spinco issues shares to Foreign Pubco Notes from Presentation Commencing in 1997 (with 2006-0215751R3), CRA started issuing favourable rulings respecting cross-border butterfly transactions which avoided the s. 55(3.2)(h) problem for such butterflies by using the three-party "vaccine" [i.e., a three-party circular exchange of consideration so that Foreign Spinco is never a shareholder of DC- see Russell, “Cross-Border Butterfly Ruling,”]. ...

Broadly speaking, taxpayers who are generally compliant and cooperative during the audit process should receive some consideration around materiality of the scope, and the number of tax years looked at. ... The integrated team will take into consideration whether the taxpayer has an effective tax control framework. ...

(d) Will the project be expanded to other sectors and if so, can CRA advise which sectors have been selected or are under consideration? ... However, we can provide the following information for your consideration. ... For example, a university whose predominant purpose is education and research would generally not acquire its main campus over 40% for the purpose of making taxable supplies for consideration. ...

That consideration will always be predicated on a review of all the facts and circumstances. ... For example, Father transfers shares of Opco (a small business corporation whose shares are eligible for the CGE) to his children in consideration for a note that is payable over 10 years, claims the capital gains reserve, but does not claim the CGE. The children transfer the Opco shares to a new Holdco in consideration for a note of Holdco, with a view to opco dividends funding note repayments. ...

Although the Income Tax Rulings program is there to provide advance comfort on the tax consequences of a transaction, as noted in IC70-6R12, CRA will not confirm the fair market value of a property, and the Rulings program is not in a position to verify the facts provided – and there are also timing considerations. ... A vendor (Vendor) sells all of its shares of a corporation (Target) to a purchaser corporation (Purchaser) in consideration for, exclusively, shares of the Purchaser. The agreement governing the purchase and sale of the Target shares (“the Agreement”) requires the Vendor to place some of the share consideration received from the Purchaser in escrow (“the Escrow Shares”) pending any downward post-closing adjustments to the purchase price. ...

In Year 1, Holdco1 transfers assets to Opco on a rollover basis in consideration for preferred shares. ... Opco redeems the preferred shares held by Holdco1 in consideration for the $500 of cash, such that there are no assets remaining in Opco afterwards except for the goodwill. ... Realization of gain accrued at the time of acquisition Assume a transfer of property with an accrued gain to a corporation on a rollover basis in consideration for preferred shares. ...

Each case could warrant different considerations based on its particular fact situation, and it may be settled differently. ... Can the CRA confirm that a subsequent transaction to ‘use’ the note or other property (including cash) received as consideration for a share redemption, such as the transfer of the note to Newco in CRA document # 2015-0604521E5, is a necessary trigger for a GAAR determination with respect to paragraph 55(3)(a)? ... Taking into consideration the input of stakeholders, the CRA further pursued its analysis of the legislative system requirements needed to implement the RTPP. ...