Search - consideration

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...

31 May 2004 External T.I. 2003-0051971E5 F- Notion de capital aux fins de 20(1)c) de la Loi-- 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) stated capital inadequately measures capital for “filling the hole” purposes where PUC is ground under s. 85(2.1) or stated capital is increased to capitalize consolidated safe income What is the measure of capital for s. 20(1)(c) purposes where shares issued as consideration for other shares on a s. 85(1) share-for-share exchange have their paid-up capital reduced from their stated capital of $800,000, to $700,000 pursuant to s. 85(2.1), or where the stated capital of shares is increased by an amount equal to consolidated safe income of the corporation? ...

A disposed of his HOLDCO preferred shares to OPCO in consideration for OPCO shares with the same tax attributes. ...

3 August 2004 External T.I. 2004-0066431E5 F- Contrat de rente et fiducie-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) "by a trust" includes any transaction performed by the trustees In 2003-004063 CRA concluded that s. 75(2) applied to a donor who, under a charitable annuity arrangement, transferred an amount to a trust in consideration for which the donor acquired a right to receive an annuity from the trust, with the excess of the amount so received by the trust over the normal cost of the annuity granted constituting a gift received by the trust. ...

A sold all of A’s Opco shares to Holdco for non-share consideration equal to the fair market value of the shares disposed of. ...

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...

A sold her Opco shares to Holdco in consideration for a term note payable over 5 years. ...

A sold her Opco shares to Holdco in consideration for a term note payable over 5 years. ...

14 June 2001 External T.I. 2000-0044935 F- Coût des actions-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base cost to Pubco of CCPC shares acquired by it in exchange for treasury shares equal to the addition to its stated capital account, rather than the Pubco shares’ FMV The requisite number of shareholders of Opco (a private corporation) agreed, at a time that the Pubco shares were trading for $2 per share, to accept an offer of Pubco to acquire each of their shares in consideration for three Pubco shares plus $4 of cash (or at their option, solely for $10 of cash). ...

CCRA was prepared to accept that s. 34.1(1) did not apply, provided that the dissolution of ABC and the creation of the new partnership was not motivated by tax considerations. ...