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CRA Response In our view, foreign tax considerations are not relevant in determining the principal purpose of the acquisition for paragraph 95(6)(b). ... Canco transfers its shares in Foreign Opco to a foreign holding corporation ("Foreign Holdco") for fair market value consideration consisting of common shares of Foreign Holdco. ...

As part of the Share offering, a tri-party Put Option Agreement among the subscriber, B Co and A Co (the "Put Option Agreement") will be entered into pursuant to which the purchaser of a Share will be entitled to exercise its Put Option to sell the purchased Share to B Co for consideration equal to the lesser of (a) the original purchase price of the Share, less any distributions received in respect of the Share, and (b) the FMV thereof at the time of exercise thereof, at the following times: (a) upon the death of the purchaser of the Share, provided such death occurs during the first XXXXXXXXXX months following acquisition of the Share; and (b) at any time between the period that is between end of the XXXXXXXXXX month and the XXXXXXXXXX month following acquisition of the Share, after the later of which times, the Put Option will expire. 18. ... Pursuant to the Put Option Agreement, A Co will pay XXXXXXXXXX% of the total Share subscription price to B Co in consideration for B Co's granting of the Put Option. 20. ...

Pursuant to an assignment agreement entered into in XXXXXXXXXX among Pubco, Pubco XXXXXXXXXX, XXXXXXXXXX ("Forco"), another wholly owned subsidiary of Pubco, and Subco, and effective on the incorporation of Subco, Pubco, Pubco XXXXXXXXXX and Forco transferred to Subco all their respective rights to participate in the XXXXXXXXXX Joint Venture and other XXXXXXXXXX projects in XXXXXXXXXX in consideration for XXXXXXXXXX common shares of Subco. ... Pubco will hold an annual general meeting in XXXXXXXXXX, at which time its shareholders will be asked to approve a reduction of capital, consideration for which will be paid by way of distribution of XXXXXXXXXX common shares of Subco (pro-rata to the shareholdings of Pubco). ...

If the personal representatives have discretion regarding the payment of income and can pay or accumulate it, the personal representatives have considerable flexibility, subject to the even-hand principle and other fiduciary considerations." ... When the beneficiaries of the estate include a registered charity or other qualified donee as defined in subsection 149.1(1), there is an additional consideration to be taken in account in determining whether a particular distribution includes any of the income earned by the estate. ...

Further, they maintain that in order for someone to subscribe for shares they must knowingly enter into a contract to purchase such a share and the Credit Union must knowingly accept the consideration offered for the share in full payment; 2)The reference to the payments on the savings account share capital as dividends, rather than as interest, is a misnomer promulgated by credit unions and such amounts are similar to insurance policy dividends. ... This deemed allotment of shares does not actually require that any shares actually be issued by the credit union, nor do we agree that a member must knowingly enter into a contract to purchase such shares and the credit union must knowingly accept the consideration offered for such shares as payment on account of, or in respect of shares. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

DISCUSSION In simple terms under a traditional co-insurance arrangement a portion of the risk (eg 90%) with regard to specified policies is ceded to a reinsurer and in consideration therefor a reinsurance premium is paid to the reinsurer. ... As in the case of a co-insurance arrangement, under a modco arrangement a portion of the risk (eg 90%) with regard to specified policies is ceded to the reinsurer in consideration for a reinsurance premium. ...

(b) In a TVC arrangement, where a 3rd party (the “broker”) receives a percentage share in the net profits of the production, as partial consideration for its services of putting the arrangement together, it is a question of fact whether the broker has acquired an equity interest in the production. ... In a TVC arrangement, where a 3rd party (the “broker”) receives a percentage share in the net profits of the production, as partial consideration for its services of putting the arrangement together, it is a question of fact whether the broker has acquired an equity interest in the production. ...

(e) The maximum price or consideration at or for which the shares without nominal or par value may be sold is $XXXXXXXXXX per share. ... No portion of the selling price (i.e., the principal amount) of XXXXXXXXXX will be allocated by the Foundation to the right inherent in XXXXXXXXXX for the Holder thereof to participate in the Lottery, nor will any consideration be stipulated as being payable for this right. 14. ...

Administrative concession It is well established in jurisprudence that, in order for a payment to qualify as a gift, the payor must, inter alia, not receive any consideration or advantage of a material character in return for the payment, and that training or education provided to children of a payor is consideration, regardless of the fact that there was no legal obligation to make the payment (see, for example, The Queen v. ...