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Each child transferred such shares to a new holding company (Holdco X or Holdco Y) in consideration for preferred shares of such holding company and the assumption by it of the interest-bearing loans, with each such holding company then potentially amalgamating with Corporation A or Newco, as the case may be. ...

Convention, CRA stated: In our view, a person who carries on the business of providing, for consideration, a service of transporting property from one place to another and who generally offers its services to the public, is a common carrier. ...

19 January 2018 External T.I. 2017-0683501E5- Flow-Through Shares-- summary under Section 38.1 Summary Under Tax Topics- Income Tax Act- Section 38.1 general paraphrase A taxpayer transfers capital property under s. 85(1) to a resource company in consideration for publicly listed common shares (the “Share”) of the resource company, and donates the Shares to a qualified donee. ...

27 May 2004 External T.I. 2003-0031231E5 F- Actions visées par règlement-gel successoral-- summary under Subclause 6205(2)(a)(ii)(A)(II) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2)- Paragraph 6205(2)(a)- Subparagraph 6205(2)(a)(ii)- Clause 6205(2)(a)(ii)(A)- Subclause 6205(2)(a)(ii)(A)(II) trusts in which nieces and nephews were beneficiaries nonetheless were deemed NAL for purposes of satisfying Reg. 6205(2)(a)(ii)(A)(II) Three brothers (A, B and C), who were the equal common shareholders of ABC, each effected an estate freeze in favour of a discretionary trust for the benefit of himself, his wife and their descendants, so that their common shares of ABC were converted into preferred "freeze shares and new common shares (assumed to be prescribed shares) were issued for nominal consideration to the respective family trusts (Trusts A, B and C). ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

Madame, decided to avail herself of the provisions of subsection 73(1) and transfer her shares to Monsieur at their adjusted cost base, the latter would be deemed to have acquired such shares at that same adjusted cost base, regardless of the consideration actually paid. ...

23 February 2001 External T.I. 2001-0066265 F- Salaire différé français-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to the family farm was not income A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to reduce the overall cost of transferring ownership to the son or daughter who remained part of the parental estate. ...

23 February 2001 External T.I. 2001-0066265 F- Salaire différé français-- summary under Subparagraph (b)(ii) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (b)- Subparagraph (b)(ii) receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to reduce the overall cost of transferring ownership to the son or daughter who remained part of the parental estate. ...