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8 September 1988 Income Tax Severed Letter 5-6310- [Donations to Registered Charities in Consideration for an Annuity] J.D. ... In our view, the word "gift" has been interpreted as being a voluntary transfer of property without consideration and without conditions. ... A secondary consideration was the ease of administration of the position for both the charities involved and the Department. ...

You indicated that the $1 consideration is specified in the legal documentation solely to ensure the agreement is legally binding and asked whether paragraph 69(1)(c) of the Income Tax Act (the Act) would apply, notwithstanding that nominal consideration of $1 would be paid. ... For example, if the agreement governing the transfer provides for consideration of $1 merely to ensure that the agreement is legally binding, the CRA may consider the transfer to be a gift. ... If it is determined that the transfer of property was a sale for inadequate consideration rather than a gift, paragraph 69(1)(c) would not apply. ...

It is our general view that the provisions of subsection 85(1) of the Act could apply where shares of one class of a corporation are transferred to the corporation for consideration consisting of shares of another class of the corporation.  Our general view would not be affected by the fact that the consideration received by the transferring shareholder includes warrants issued by the corporation.  ... Consequently, the fair market value of the warrants would constitute non-share consideration received by the transferor in the course of disposing of eligible property to a taxable Canadian corporation. ...

It is our general view that the provisions of subsection 85(1) of the Act could apply where shares of one class of a corporation are transferred to the corporation for consideration consisting of shares of another class of the corporation. Our general view would not be affected by the fact that the consideration received by the transferring shareholder includes warrants issued by the corporation. ... Consequently, the fair market value of the warrants would constitute non-share consideration received by the transferor in the course of disposing of eligible property to a taxable Canadian corporation. ...

7 November 1991 Income Tax Severed Letter- Deductibility of Consideration Paid for Player Rights Unedited CRA Tags 9 Dear Sirs: Re: Deductibility of Consideration Paid for Player Rights This is in reply to your letter of XXX concerning the deductibility, for purposes of the Income Tax Act, of consideration paid for player rights in the following hypothetical situation: "A partnership (the "Partnership") will pay a fee to obtain membership in a professional sports league with all the privileges of membership, including a franchise for a team in a particular city, and the rights to select players with league experience from the present teams in the league and to priority drafting position in 1992 player drafts (such rights collectively referred to as the "Player Rights"). ...

29 November 1989 Income Tax Severed Letter RRRR138- Letters for consideration by another Revenue Canada employee Unedited CRA Tags none As recently discussed with Mr. ... Jolie of your office, we are forwarding for your consideration and reply the yellow file folder containing XXX letter of October 31, 1989 addressed to the Honourable Otto Jelinek. ...

Principal Issues: (1) Do exploration expenses incurred by a corporation on property owned by a wholly-owned subsidiary for no consideration qualify as CEE of the corporation? ... However, where the exploration work is conducted for no consideration, it is conceivable that the corporation is conducting the exploration activities as the agent for its wholly-owned subsidiary. ... In arm's length situations, the corporation incurring the exploration expenses on properties that it does not own would normally do so for fair market value consideration. ...

3 December 1992 External T.I. 9226025 F- Loss On Guarantee For Inadequate Consideration Unedited CRA Tags 40(2)(g)(ii)   922602 24(1) L. ... Specifically, you asked the Department to confirm that subparagraph 40(2)(g)(ii) of the Act would not be applied to deny a capital loss in the following circumstances: €     the taxpayer received inadequate consideration in return for guaranteeing a debt of the corporation. €     the loss on the guarantee occurred once the taxpayer was no longer a shareholder. €     the taxpayer was a shareholder at the time the debt of the corporation was guaranteed. €     all the other conditions outlined in paragraph 6 of IT-239R2 are met. ... It is our view the same reasoning would apply in respect of the application of subparagraph 40(2)(g)(ii) of the Act in respect of a loss on a guarantee that was given for less than adequate consideration. ...

7 July 1990 Income Tax Severed Letter- Tax consequences to a farmer of receipt of proceeds from granting right of access and easement to a vineyard and receipt of consideration for permanent damages to vineyard as result of underground gas pipeline constructed under right of way Unedited CRA Tags 14(1), 14(1)(a), 20(1)(b), 110.6(2) Dear Sirs: This will reply to your letter of June 7, 1990 requesting our views on the tax consequences to a Canadian farmer of the receipt of proceeds from the granting of a right of access and easement to his vineyard and the receipt of consideration for permanent damages to his vineyard as a result of an underground gas pipeline constructed under the right of way. ... Therefore the consideration received by him for the right of access and easement would be an amount described in subparagraph 14(5)(a)(iv). ...

3 December 1990 Ministerial Correspondence 903344 F- Shares Issued as Consideration for All or Substantially All of the Assets Used in an Active Business Unedited CRA Tags 54.2, 96 24(1) 903344   C. ... You question whether the word "person" includes a partnership, for the purposes of section 54.2 of the Act, where a partnership has disposed of property that consisted of all or substantially all of the assets used in an active business carried on by that partnership to a corporation for consideration that includes shares of the corporation. ...