Search - consideration

B of any right, interest or holding in Opco to Portfolioco pursuant to paragraph 69(1)(b)… [for deemed] consideration equal to the fair market value of the property disposed of. ...

17 November 1999 External T.I. 9901265- 97(1) AND A RESERVE-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) "[W]here and 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. ...

26 October 2020 External T.I. 2020-0856791E5- CEWS- meaning of inflow-- summary under Subsection 125.7(4) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(4) CRA will not issue rulings or TIs on what is normal accounting practice for CEWS purposes Regarding a question as to the timing of recognition of qualifying revenue, whose definition in s. 125.7)1) referred to the “inflow” of cash, receivables or other consideration arising in the course of the eligible entity’s ordinary activities in Canada, CRA stated: Subsection 125.7(4) enacts that the qualifying revenue of an eligible entity is generally determined in accordance with its normal accounting practices. ...

15 February 2001 External T.I. 1999-0008405 F- Lien de dépendance-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) secured promissory note potentially could give rise to de facto control Y sold his wholly-owned corporation (Yco) to a corporation (Xco) owned by an unrelated individual (X), in consideration for $100,000 in cash (being the only asset of Xco) and an interest-bearing promissory note for $400,000, secured by a mortgage on Yco's property). ...

15 February 2001 External T.I. 1999-0008405 F- Lien de dépendance-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) holding of secured note for 80% of purchaser’s assets potentially could give rise to de facto control Y sold his wholly-owned corporation (Yco) to a corporation (Xco) owned by an unrelated individual (X), in consideration for $100,000 in cash (being the only asset of Xco) and an interest-bearing promissory note for $400,000, secured by a mortgage on Yco's property). ...

7 November 2000 External T.I. 2000-0040615 F- OPTIONS ET CLAUSE DE CAPACITE DE GAIN-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) granting of earnout option may require full recognition under s. 49(1) on grant date/ legal form of option v. share sale generally followed The shareholders, in consideration for granting the acquirer an option to acquire their shares in two years for a nominal sum, were entitled to receive, over the two-year period an amount equal to the agreed sale price (calculated on the basis of the corporation's profitability) less the nominal exercise price. ...

The Agency indicated that the cost of the Opco shares to the purchaser (Pubco) acquired for Pubco shares would be determined pursuant to s. 85.1(1)(b) even if the vendor included in its income the taxable capital gain from the disposition of the shares, and regardless of the amount allocated by Pubco to the stated capital of the shares of its capital stock issued as consideration for the exchanged Opco shares. ...

8 June 2000 External T.I. 1999-0006105 F- TRANSFERT DE BIENS A UN CONJOINT-- summary under Subsection 74.1(1) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt An individual transferred property to his spouse in consideration for her owing the purchase price to him. ...

The taxpayer transfers the shares to the first lender as the sole consideration for the settlement of the $3,000 debt, with $1,000 loan left outstanding. ...

Subsection 146(9) concerns dispositions of property by an RRSP for less than fair market value and would otherwise apply to include any excess of the fair market value over the consideration received in the income of the annuitant. ...