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The Partnership immediately disposed of all of its properties to a taxable Canadian corporation (the "Corporation") of which Partner B was the sole shareholder in consideration for the issuance of promissory notes and common shares (and elected under s. 85(2)) but with title to all assets staying the name of the Partnership. ...

The Partnership immediately disposed of all of its properties to a taxable Canadian corporation (the "Corporation") of which Partner B was the sole shareholder in consideration for the issuance of promissory notes and common shares (and elected under s. 85(2)) but with title to all assets staying the name of the Partnership. ...

A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ...

A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ...

A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ...

Turning to the "resident beneficiary" requirement, which required that there be a "connected contributor," CRA stated: When determining if an estate created on someone's death has a connected contributor, the relevant consideration is whether the deceased was a resident of Canada immediately before death or within 18 months of death. ...

It follows in our view that amounts paid to a qualifying person by a purchaser of EFA contracts because of the potential for future profits that could be derived from those contracts for future services to be rendered would not be paid in consideration for the disposition, by the qualifying person, of its interest in an EFA or an interest in a trust governed by an EFA. ...

The elections in subsections 45(2) and 45(3) cannot be made in the situation under consideration. ...

Furthermore, the taxable income and taxable capital employed in Canada of a subsidiary for the taxation year of its winding-up must be taken into consideration for the purposes of paragraphs 157(1.3)(b) and 157(1.4)(b) to determine whether the parent qualifies as a SCCPC [small CCPC] since the parent and the subsidiary are associated in the course of the particular taxation year by virtue of paragraph 256(1)(a). ...

26 June 2013 External T.I. 2013-0490711E5 F- Disposition en contrepartie de 1$-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) nature of Quebec gift Could the acquisition of a property for consideration of one dollar qualify as an acquisition by gift for purposes of s. 69(1)(c)? ...