Search - consideration

X transfers high-low preferred shares of Opco 1 to Opco 2 (both held by him and related persons) in consideration for a note, such that he is deemed by s. 84.1(1)(b) to receive a dividend. ...

Parentco will transfer to Sisterco a portion of its Holdco common shares on a s. 85(1) rollover basis in consideration for redeemable preferred shares. ...

The new rules in proposed subsection 248(30) of the Act do not create a presumption of a gift where the value of the consideration received by a donor is less than 80% of the value of the property donated but there is otherwise no gift because of the absence of an intention to make a gift. ...

After noting its position that where a lease had a bargain purchase option, a portion of each lease payment was to be treated as allocable to consideration paid for the option and not as deductible rent, CRA stated: [T]he payment of $5,000 made by Corporation B would, in all likelihood, be attributable to the option to purchase the property, which would constitute the acquisition cost of this option for Corporation B and the proceeds of disposition of this option to Corporation A. ...

Holdco had acquired the preferred shares of Employeeco (having no significant safe income) over the past five years as consideration for the transfer in each year of Opco common shares to Employeeco on a s. 85(1) rollover basis. ...

Holdco had acquired the preferred shares of Employeeco (having no significant safe income) over the past five years as consideration for the transfer in each year of Opco common shares to Employeeco on a s. 85(1) rollover basis. ...

A, who owned all the shares of Lossco, which had disposed of all the assets of its (unspecified) business for cash, disposed of those shares for FMV cash consideration to Profitco, which was owned equally by her and her three siblings. ...

The consideration for the goodwill, which has a value of $140,000 that consists of the assumption of a $100,000 loan and the issuance of preferred shares with a redemption amount of $40,000. ...

X) now wants to roll the business into a Newco under s. 85(1), electing at $100,000 (which, in the posited example, equals the non-share consideration in the form of a loan to be assumed by Newco). ...

15 January 2018 External T.I. 2017-0722961E5- Winding-up of a partnership-- summary under Subsection 98(5) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(5) amalgamation of a former partner with a former partnership subsidiary within 3 months of the partnership wind-up ousts s. 98(5) The Partnership, whose 0.01% general partner (GPCo) is wholly-owned by its 99.99% limited partner (LPCo), transfers it business assets (the “Business Assets”) to newly-incorporated subsidiary (“Newco”) under s. 85(2) in consideration for Newco shares. ...