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In the situation under consideration, neither of these paragraphs applies. ...

24 June 2015 External T.I. 2015-0575911E5 F- Benefit to shareholder or conferred on a person CRA Tags 15(1) 15(1.4)(c) 56(2) 246(1) Principales Questions: 1- Corporation (Opco) with 4 shareholders disposes of an asset to the spouse of one the shareholders for consideration less than FMV. 2- What if the 4 shareholders are shareholders of Holdco and all the shares of the capital stock of Opco are held by Holdco. 3- What if the 4 shareholders are brothers. ...

However, even without the consideration of the source it is likely that a FTC will not be available on the basis that the tax paid to the Japanese tax authorities was a voluntary payment and not "tax" within the meaning of subsection 126(1). ...

Les facteurs à prendre en considération pour déterminer le statut de résidence d'un particulier aux fins de l'impôt sur le revenu sont décrits dans le Folio de l'impôt sur le revenu S5-F1-C1 The factors to be taken into account in making the determination of an individual's residency status for the purpose of income tax are described in the Income Tax Folio S5-F1-C1. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX. 8. ...

Pursuant to the terms of a tax-deferred reorganization in Israel, Foreign Parent will acquire from Foreign Holdco, for no consideration, the shares of Canco2 held by Foreign Holdco. ...

RCA provides guarantee or security for third-party loan to specified beneficiary You ask whether we would consider an RCA strip to have occurred if the specified beneficiary pays the RCA custodian an "arm's length commercial" fee as consideration for the RCA custodian guaranteeing, or permitting the RCA property to be used as security for, a loan made to the specified beneficiary from an arm's length financial institution. ...

That is because Canco did receive consideration for its disposition of the shares of FA1 in the form of the FA2 shares it received; and 3. unless Canco elects not to have subsection 87(8) of the Act apply, paragraph 87(4)(b) of the Act, as modified by subsection 87(8), will apply to the shares of FA2 distributed to Canco to deem them to have been acquired by Canco at a cost equal to the proceeds for which the FA1 shares were deemed disposed of pursuant to paragraph 87(4)(a) of the Act. ...

The classification of the proposed amounts to be paid to the international students, and the students’ status as full-time or otherwise of the Canadian university, are therefore important considerations in determining the taxability of the amounts. ...

Corporation A acquired the Property on XXXXXXXXXX and issued its shares as consideration for the Property. 12. ...