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6 November 2001 External T.I. 2001-0105945 F- INTERETS LUDCO SINGLETON-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) scope of study on impact of Ludco and Singleton CCRA was studying the impact of Ludco and Singleton on various issues including the deductibility of interest on money borrowed to pay dividends or redeem shares, to acquire the shares of a corporation that is amalgamated with the acquiring corporation, to make a loan at less than a reasonable rate of interest or to honour a guarantee for inadequate consideration, to acquire common or preferred shares or to make interest-free loans to employees. ...

1 March 2002 External T.I. 2002-0118215 F- ACTIONS EMISES GRATUITES AUX EMPLOYES-- summary under Subsection 7(1.1) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.1) s. 7(1.1) continues to apply after issuing employer ceases to be a CCPC After indicating that the s. 7 rules were applicable to shares issued for no consideration to employees of a CCPC, CCRA went on to describe the application of the ss. 7(1.1) and 110(1)(d.1) rules, and stated: [S]ubsection 7(1.1) will continue to apply even if the corporation ceased to be a CCPC after the shares in question were issued. ...

17 November 1999 External T.I. 9901265- 97(1) AND A RESERVE-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) "[W]here an individual transfers property to a partnership under subsection 97(2) of the Act and receives, in addition to a partnership interest as consideration, a promissory note payable over, say, five years, the agreed amount would include the note and this amount would be deemed to be the proceeds for the individual and the cost to the partnership. ...

17 February 2021 External T.I. 2018-0768051E5 F- Contrat de crédit-bail-- summary under Substance Summary Under Tax Topics- General Concepts- Substance lease payments, but not the lease itself, could be recharacterized Regarding a lease of a truck tractor with a term of 48 months and a bargain purchase option at maturity, CRA indicated that the monthly rental payments should be allocated between deductible rental payments for the use of the vehicle and consideration for the option, which would be added to the adjusted cost base of the option. ...

After noting that “qualifying revenue" generally referenced “the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity,” CRA stated: [A] member's share of the profits of a partnership, as allocated to the member pursuant to subsection 96(1) and in accordance with the partnership agreement, is not "qualifying revenue" to the member …. ...

5 February 2001 External T.I. 2001-0067135 F- Dividend-General-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) application of s. 84.1 on sale of 50% shareholding to corporation owned by the transferor and his spouse A, an individual holding 50% of the shares of Bco, with a nominal ACB and PUC, sells those shares to Cco in consideration for a $100,000 note of Cco. ...

CCRA indicated that “its concern is to ensure that the total value of the consideration received in shares (redemption value) and non-shares is equal to the fair market value of the property disposed of pursuant to subsection 85(1).” ...

This would not satisfy CCRA’s “concern … to ensure that the total value of the consideration received in shares (redemption value) and non-shares is equal to the fair market value of the property disposed of pursuant to subsection 85(1).” ...

14 July 2000 External T.I. 2000-0018725 F- TRANSFER ENTRE CONJOINT-- summary under Subparagraph 20(1)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) not appropriate to comment on an interest-deductibility issue under appeal Shares of an SBC of the taxpayer were sold to a spouse in consideration for his assumption of the taxpayer's mortgage on the residence. ...

"Attribution Rules")-- summary under Subsection 74.5(2) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(2) Where an individual (the transferee) has acquired an income-producing property from his spouse (the transferor) in consideration for a demand promissory note bearing interest at the prescribed rate in effect at the time of the transfer, a subsequent agreement of the transferor to make a loan to the transferee at the lower prescribed rate prevailing at the time of the loan, with the loan proceeds being used to repay the demand promissory note, would not result in the exception in s. 74.5(2) being applicable because the proceeds of the loan would be used to repay the note rather than to generate any income or produce gain. ...