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The solution adopted was for PWR to then transfer high basis assets to the Holdcos in consideration for preferred shares of the same class, so that the PUC of the preferred shares held by Mr. ...

Ignoring the significant complicating effect of the transactions with his sister, he transferred his shares under s. 85(1) to a new holdco (“P Pom”) in consideration for Class G shares of P Pom (with a nominal paid-up capital and a deemed cost equaling the “soft” ACB of the transferred shares, and for Class A common shares of P Pom with a nominal PUC and ACB. ...

Instead, he transferred the shares to a new holding company (P Pom) under s. 85(1) in consideration for high ($1M) basis Class G shares and low basis Class A shares, and redeemed the Class G shares. ...

In consideration, they were permitted to keep the recoveries of alternative minimum tax made by them in the subsequent taxation years. ...

Canada, 2018 FCA 209-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) not each transaction in series effecting an estate freeze had that objective Prior to the sale of a corporation ("Groupe AST") to a third party, its individual shareholder (“Jobin”) transferred his shares of Groupe AST on a s. 85(1) rollover basis to a holding company (“276”), and then the adjusted cost base of the shares of Groupe AST was stepped up in the hands of 276 to fair market value through a combination of Groupe AST increasing the stated capital of its shares, thereby generating a s. 84(1) deemed dividend to the taxpayer which was reported by it as a capital gain under s. 55(2), and of 276 transferring the Groupe AST shares on a non-rollover basis to a Newco formed by Jobin (“9144”) in consideration for Class A common shares with a high ACB. ...

Canada, 2019 FCA 57-- summary under Subsection 16(1) Summary Under Tax Topics- Income Tax Act- Section 16- Subsection 16(1) s. 16(1) can only apply to a debtor if it equally applies to the creditor As part of a complex set of transactions, a predecessor of the taxpayer agreed to assume a $225M loan that was due in perhaps 43-years’ time and that was non-interest-bearing (except in the remote event of oil production from the Beaufort Sea) in consideration inter alia for the payment to it of $17.5 million by the debtor. ...

The Tax Court (D’Arcy J) had found that, in fact, on the same day that the limited partnership acquired the permit rights from its general partner (“Kinderock”), it had transferred their beneficial ownership to Devonian (on an s. 85(2) rollover basis) in consideration for shares, so that its fleeting beneficial ownership of those assets did not qualify them as being used in a Canadian active business, as required under the s. 110.6(14)(f)(ii) test. ...

Similarly, he stated (at para. 55): [T]here is no doubt that broad expressions such as “taxable supply” and “commercial activity” … must be interpreted irrespective of considerations of lawfulness, public order or morality. ...

. … The appellant also argues that he was denied procedural fairness because he legitimately and reasonably expected that he would be provided the same process considerations as the successful SDL Optics employees. … I disagree. ...

Colitto transferred, for nominal consideration, real estate to her in 2008. ...