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GST M 200-3 "Calculation of the Small Suppliers' Threshold" under "Determining the Value of Consideration" -- summary under Subsection 240(1)

GST M 200-3 "Calculation of the Small Suppliers' Threshold" under "Determining the Value of Consideration"-- summary under Subsection 240(1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1) The small supplier threshold is calculated by determining the value of taxable supplies made by the person or an associate on a world-wide basis. ...

IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances" -- summary under Subsection 246(1)

IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances"-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) Former s. 245(2) may have been applied in situations where there is a material benefit to other shareholders as a result of a minority shareholder making a loan to, or honouring a guarantee in respect of, a Canadian corporation controlled by him and members of his family. ...

Brian Darling, "Revenue Canada Perspectives" in Income Tax and Goods and Services Tax Considerations in Corporate Financing, 1992 Corporate Management Tax Conference Report (Canadian Tax Foundation, 1993), 5 -- summary under Subsection 5907(6)

Brian Darling, "Revenue Canada Perspectives" in Income Tax and Goods and Services Tax Considerations in Corporate Financing, 1992 Corporate Management Tax Conference Report (Canadian Tax Foundation, 1993), 5-- summary under Subsection 5907(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(6) 1-20, question 7, at 5:13: [w]hat is reasonable in the circumstances can be determined on a case-by-case basis. ...

Bulletin LTT 10-2000 Transactions for Nominal Consideration November 2000 -- summary under Subsection 3(1)

Bulletin LTT 10-2000 Transactions for Nominal Consideration November 2000-- summary under Subsection 3(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Section 3- Subsection 3(1) Partitioning of a Co-tenancy Where a partitioning of land takes place and each or any of the "co-tenants" receives land equal in value to their original interest in the whole parcel, no tax will be payable. ...

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023 -- summary under Section 175.1

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Section 175.1 Summary Under Tax Topics- Excise Tax Act- Section 175.1 Michael, a GST/HST-registered sales person, uses his car to meet clients. ...

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023 -- summary under Section 272

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Section 272 Summary Under Tax Topics- Excise Tax Act- Section 272 Parent a continuation of wound-up subsidiary for s. 156(2) purposes 60. ...

P-222 - "Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act (the "ETA")", 10 December 1998 -- summary under Section 159

P-222- "Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act (the "ETA")", 10 December 1998-- summary under Section 159 Summary Under Tax Topics- Excise Tax Act- Section 159 To convert from foreign currency into Canadian currency for purposes of Part IX of the Excise Tax Act, a person may only use the rate of exchange from: the source used for an actual conversion (i.e. foreign currency is exchanged for Canadian dollars); the source the person typically uses for actual conversions; a Canadian chartered bank; the Bank of Canada; or the rate provided by the Customs Branch of the Department for purposes of converting the value for duty of imported goods. ...

Suncor/COS -- summary under Shares

On January 17, 2016, following negotiations, Suncor and the Corporation entered into a Support Agreement in which Suncor agreed to increase the consideration to 0.28 of a Suncor Share. ... U.S. tax considerations. Suncor intends for the previous offer, the Amalgamation and the subsequent amalgamation between Amalco and Holdco, taken together (the "exchange transaction"), to be treated as a reorganization within the meaning of Code s. 368(a). ...

Nuvo/Crescita -- summary under Butterfly spin-offs

The granting of fresh options by Holdco to optionholders is expressed to be part consideration for the distribution. ... Each Nuvo Butterfly Share acquired by a Resident Shareholder pursuant to the Arrangement will be transferred by the Resident Shareholder to Crescita in consideration for the issuance to the particular Resident Shareholder of one Crescita Common Share. ... U.S. tax considerations. S. 355. Code s. 355 requires that (in addition to the Arrangement being treated as a distribution of the stock of Crescita Common Shares notwithstanding its form as a series of transactions other than a distribution): the transaction be effected for one or more corporate business purposes; the transaction not be used "principally as a device for the distribution of the earnings and profits" of Nuvo or Crescita; and that both Nuvo and Crescita continue to be engaged after the transaction in one or more trades or businesses actively conducted by Nuvo or its subsidiaries throughout the 5-year period ending on the date of the deemed distribution. ...

Hecla/Aurizon -- summary under Canadian Buyco

The consideration for each Aurizon share is (i) cash of $4.75 per share (the "Cash Consideration"), or (ii) 0.9953 of a Hecla share (the "Share Consideration"), or (iii) $3.11 in cash and 0.3446 of a Hecla share (the "Cash and Share Consideration"). ... Although Aurizon shareholders will be able to elect between consideration alternatives, the total cash and share consideration will be limited to $513.6M and 57M Hecla shares (so that if all shareholders elected for the Cash Alternative or the Share Alternative, each shareholder would effectively receive the Cash and Share Consideration). ... Under the Arrangement, the consideration will consist of approximately 35% share consideration and 65% cash consideration. ...

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