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To the extent that the member, in consideration for the shares received on subscription, has paid an amount equal to the paid-up capital in respect of such shares, the provisions of subsection 84(1) of the Act will not apply. ...

. … Expenses paid to a “private health services plan” as a premium, contribution or other consideration in respect of, among others, the individual or the individual's spouse generally qualify as medical expenses under paragraph 118.2(2)(q) except to the extent that the payment was deducted by the individual as a business expense under subsection 20.01(1). ...

7 November 2000 External T.I. 2000-0040615 F- OPTIONS ET CLAUSE DE CAPACITE DE GAIN-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) IT-426 cost-recovery method not available where earnout is embedded in the variable proceeds received for the granting of a share-sale option with nominal exercise price 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. ...

In relation to a sale of the shares of Opco by the two spouses to the Holdco of their adult child for non-share consideration, would Realtyco be considered a relevant group entity for purposes of s. 84.1(2.31)(c)(iii) and s. 84.1(2.32)(c)(iii), so that continued control of Realtyco by Mr. ...

CRA confirmed that, in relation to a sale of the shares of Opco by the two spouses to the Holdco of their adult child for non-share consideration, Realtyco would not be considered a relevant group entity, so that continued control of Realtyco by Mr. ...

16 November 2011 External T.I. 2011-0423861E5 F- paragraph 53(1)b)-- summary under Paragraph 53(1)(b) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(b) example of application of s. 53(1)(b) on dirty s. 85 exchange of common shares with partial SIOH for high PUC/ACB prefs and low PUC/ACB common shares Holdco, whose common shares of Opco have a nominal adjusted cost base ("ACB") and paid-up capital ("PUC"), a fair market value ("FMV") of $2 million and safe income on hand ("SIOH") attributable to those shares of $900,000, increases the PUC of those shares by $1 million, and transfers those common shares (or to be more precise, new common shares issued in replacement therefor on the PUC increase) to Opco for cancellation in consideration for the issuance by Opco of (i) preference shares of Opco having an FMV, PUC and ACB (determined under s. 85(1)(g)) of $1 million; and (ii) common shares having a FMV of $1 million and nominal PUC and ACB. ...

After noting that s. 97(2) permits a taxpayer to dispose of property on a tax-free basis to a partnership if, among other things, the taxpayer is a member of the partnership immediately following the disposition, CRA stated: [T]here would be a disposition of the initial interest if the interests in income and in capital received in consideration had rights and characteristics sufficiently different to be distinguishable from those of the initial interest. … It should be noted that the totality of the interests of a partner held in a partnership constitute a single property of the partner and represent its interest in the partnership for purposes of the Act. ...

The deductibility of the discount to the Canadian Taxpayer, would be subject to the considerations listed in IT Bulletin 188R and must meet the provisions of section 67 and section 69 of the Act. ...

However, given CRA's interpretation of the fees as being consideration for services, they would not constitute royalties under Article XII of the Canada-US Income Tax Convention, and they would not be taxable under Art. ...

Opco transfer the real estate to Realtyco in consideration for preferred shares of equal value, electing under s. 85(1). ...