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24 October 1990 External T.I. 9024635 F- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21) timber resource property 24(1) 5-902463   C.K. ...

Income Tax Considerations Relating to the Inheritance Pursuant to subsection 70(5.2), when a taxpayer dies owning CRP, he is deemed to have disposed of the CRP immediately before death and to have received proceeds of disposition equal to its fair market value (“FMV”) at that time. ... Income Tax Considerations Relating to the Disposition of CRP The income tax consequences that arise on a disposition of CRP will depend on whether the CRP is an oil and gas property or a mineral property. ... Income Tax Considerations: When Mr. X died he would have been deemed to have disposed of the Property for proceeds of disposition of $1 million, in accordance with paragraph 70(5.2)(a) and the Taxpayer would have been deemed to have acquired the Property at a cost of $1 million pursuant to paragraph 70(5.2)(b). ...

Other Considerations: In addition to the rules respecting qualified investments for RRSP's, certain registration requirements will affect the manner in which the annuity purchase is handled. ...

Other Considerations It should be noted that a proposed amendment to Class 17 of Schedule II to the Regulations, which was announced on March 16, 2001, provides that electrical generating equipment (subject to certain exceptions that are not relevant to your situation) acquired after February 27, 2000 will be included in that class by virtue of proposed paragraph (a.1) thereof. ...

General Tax Considerations Relating to Different Aspects of the Project 1. ...

23 August 2016 External T.I. 2015-0614981E5- Foreign Share for share Exchange Unedited CRA Tags 85.1(5), 85.1(6) Principal Issues: In the context of a foreign share for share exchange, where a vendor receives newly-issued shares of the purchaser and non-share consideration for each exchanged share, but the purchaser's offer does not indicate which fraction of each exchanged share is exchanged in consideration for the newly issued shares of the purchaser and which fraction of each exchanged share is exchanged for non-share consideration, can the rollover in subsection 85.1(5) still apply to the portion of the tendered shares that are exchanged solely for share consideration? ... The fraction of the total consideration that this cash represents could not be determined until the date of the exchange because the total exchange consideration was dependent upon the average trading price of Foreign Purchaser’s shares (within a fixed range) immediately before the exchange. ... The purchaser’s offer must clearly indicate which fraction of each exchanged share is exchanged in consideration for the newly issued shares of the purchaser and which fraction of each exchanged share is exchanged for non-share consideration. ...

Teixeira (613) 957-2095 November 16, 1998 Dear Sir: Re: Transfer of eligible capital property and redemption of shares received as consideration This is in reply to your letter of July 28, 1998 in which you requested our comments on the redemption of shares issued by a corporation in consideration for the transfer of eligible capital property, in respect of a business of an individual, pursuant to subsection 85(1) of the Income Tax Act. ... On the redemption of the shares issued in consideration for the transfer of the eligible capital property, the amount paid by the corporation on the redemption of those shares in excess of the amount of the paid-up capital in respect of those shares immediately before the redemption is deemed by subsection 84(3) to have been a dividend received by the holder of those shares. ...

Teixeira (613) 957-2095 November 16, 1998 Dear Sir: Re: Transfer of eligible capital property and redemption of shares received as consideration This is in reply to your letter of July 28, 1998 in which you requested our comments on the redemption of shares issued by a corporation in consideration for the transfer of eligible capital property, in respect of a business of an individual, pursuant to subsection 85(1) of the Income Tax Act. ... On the redemption of the shares issued in consideration for the transfer of the eligible capital property, the amount paid by the corporation on the redemption of those shares in excess of the amount of the paid-up capital in respect of those shares immediately before the redemption is deemed by subsection 84(3) to have been a dividend received by the holder of those shares. ...

Would a subsection 162(7.3) penalty apply in various scenarios involving a tax preparer that prepares a return for consideration, but for some reason, the taxpayer decides to file that prepared return or a different return in paper format? ... Subsection 150.1(2.3) requires a tax preparer to file any return of income prepared by the tax preparer for consideration by way of electronic filing, except that 10 of the returns of corporations and 10 of the returns of individuals may be filed other than by way of electronic filing. ... Would the subsection 162(7.3) penalty apply where a tax preparer prepares a return for consideration, but for some reason, the taxpayer decides to file that prepared return or a different return in paper format? ...

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. ...