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Quebeco 2 transfers real property with a fair market value of $100,000 and a nominal cost amount to Quebeco 3 under s. 85(1) in consideration for $100,000 of preferred shares. ...

5 December 2012 External T.I. 2012-0445891E5- Contributed Surplus and Thin Capitalization-- summary under Subsection 18(4) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(4) IFRS not followed A non-resident corporation (NRco) transferred its shares of Canco, having a cost and paid-up capital of $100 and a fair market value of $1,000 to Newco in consideration for shares of Newco having a stated capital of $1,000, but with the paid-up capital being ground down to $100 under s. 212.1(1)(b). ...

[T]he individual could designate an agreed amount for the purposes of section 85 that was between the fair market value of the land and its adjusted cost base (but that would be higher than the adjusted cost base), in order to reduce the loss that was deemed to be nil and to increase the cost of the land to the acquirer as well as the cost of the consideration received by the vendor. ...

10 August 2015 External T.I. 2015-0602751E5- Capital gains deduction and section 84.1-- summary under Paragraph 84.1(2)(a.1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1) statement of purpose and simple examples of s. 84.1 application The taxpayer and his wife acquire all the shares, qualifying as qualified small business corporation shares, of a corporation (the "Corporation") directly from XX (the "Shareholder") in consideration for a promissory note having a principal amount equal to the fair market value of the acquired shares. ...

Generally, a plan…[is] a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are to be used to provide an annuity or other periodic payment on or after the employee's retirement. ...

B, for no consideration, ½ of her preferred shares, thereby realizing under s. 73(1) proceeds of disposition deemed to be equal to the ACB of those shares of $500,000. ...

(“Holdco 2 Inc.”) in exchange for the issuance of preferred shares Holdco Inc. will transfer a rental property and its shares of Opco 1 Inc. to Holdco 2 Inc. on a s. 85(1) rollover basis in consideration for the issuance of preferred shares the resulting cross preferred shareholdings will be redeemed and the resulting notes settled. ...

., someone who would not receive any benefits from the municipality as employment or business income) would reference the situation where any consideration paid “does not adequately reflect the amount of work performed nor the quality of the services provided (whereas “where the amount of remuneration paid … is sufficient to influence their involvement or participation, it is very likely that the remuneration is taxable as employment income or income from a business”), CRA went on to say that, in the context of s. 81(4): The volunteer firefighters we are referring to are not necessarily volunteers in the sense established above. ...

The application of s. 89(8), without taking into consideration variable C, would result in a particular LRIP addition for Target. ...

Corporation A sells the assets of three of its restaurants to Newco under s. 85(1) in consideration for the assumption of debt and Newco preferred shares. ...