Search - consideration

24 September 1996 Income Tax Severed Letter 9613015- Gift — consideration Unedited CRA Tags 118.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Paragraph 3 of Interpretation Bulletin IT-110R2 states that a gift for income tax purposes, is a voluntary transfer of property without valuable consideration. ... No valuable consideration- no benefit of any kind- to the donor or to anyone designated by the donor may result from the payment. ...

29 May 1991 Ruling 910341 F- Dispositions- Absence of Consideration Unedited CRA Tags 50(1)(b)(iii), 54 disposition 24(1) This is in reply to your letter dated February 1, 1991 regarding the tax treatment 24(1) The Facts you have presented follow. Facts 24(1) Issues 24(1) Our Comments Interpretation Bulletin IT-460, Dispositions- Absence of Consideration states in Paragraph 4 that "The following occurrences do not constitute a disposition (within the meaning of paragraph 54(c)) of a share of a corporation... ...

7 August 1991 Income Tax Severed Letter- Fair Market Value of Shares Received as Consideration for the Shares Transferred to a Corporation Unedited CRA Tags none Dear Sirs: Re: Advance Income Tax Ruling XXX We are writing in response to your letter of July 15, 1991 wherein you requested our views XXX. ... Comments As stated in the reply to question 13 at the 1980 Revenue Canada Round Table, the Department is concerned with the fair market value of the shares received as consideration for the shares transferred to the corporation pursuant to subsection 85(1) of the Income Tax Act (Canada) (the “Act”). ...

7 May 1991 Income Tax Severed Letter- Dispositions- Absence of Consideration Unedited CRA Tags 54(c), 50(1)(b)(iii) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Facts XXX Issues XXX Our Comments Interpretation Bulletin IT-460, Dispositions- Absence of Consideration states in Paragraph 4 that "The following occurrences do not constitute a disposition (within the meaning of paragraph 54(c)) of a share of a corporation... ...

4 April 1990 Income Tax Severed Letter ACC9176- Transfers for Inadequate Consideration 24(1) April 4, 1990 PART II Transfers for Inadequate Consideration 85(1)(e.2); 86(2); 87(4) and 51(2) The corporate reorganization sections in the Income Tax Act contain provisions which impose "penalties" for transfers to or share exchanges with corporations where the value of the property given up exceeds the value of the property received, and "it is reasonable to regard any part of such excess as a benefit that the taxpayer desired to have conferred on a person related to the taxpayer. ...

26 October 1990 Internal T.I. 90M11357 F- Loan Guarantee from Non-resident for No Consideration Unedited CRA Tags n/a CTF- 1990 Conference Report QUESTION I 69 Withholding Tax- Dividends Paragraph 2(a) of Article X of the Canada-U.S. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee Unedited CRA Tags 118.1(13) Principales Questions: Est-ce que la « JVM de toute contrepartie reçue par le donataire reconnu pour la disposition du TNA » au paragraphe 118.1(13) se limite à la notion de « produit de disposition » prévue à l’article 54? / Is the "FMV of any consideration received by the donee for the disposition" in subsection 118.1(13) limited to the notion of "proceeds of disposition" in section 54? ... Raisons: La notion de "contrepartie" est plus large. / The notion of "consideration" is broader. ...

19 March 2001 External T.I. 2001-0074075- Non-share consideration- 85 rollover Unedited CRA Tags 85(1)(b)\ Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

9 February 1990 Internal T.I. 59439 F- Inadequate Consideration- Redemption of Shares Unedited CRA Tags 69(1)(b), 84(3) 19(1) File No. 5-9439   S. ...

7 November 1990 Income Tax Severed Letter- Consideration of Preferential Pricing on RRSP as Permitted Benefits Unedited CRA Tags 146(2)(c.4) Dear Sirs: Re: Benefits permitted under section 146(2)(c.4) This is in reply to your letter of October 23, 1990, requesting our opinion whether preferential pricing on registered retirement saving plans ("RRSPs") for certain groups was allowed. ...