Search - consideration

Before the expiration of the two-year s. 90(8)(a) limit, Canco sells its shares of FA to Foreign Parent for cash consideration. ...

D transferred D’s Opco shares to Holdco in consideration for a non-voting preferred share and a note. ...

Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired..... ...

A, the Directorate stated: Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired …. ...

In this case, consideration should be given to requiring any excess investment earnings to be withdrawn from the Plan. ...

12 January 2017 Internal T.I. 2016-0636911I7- Standby Charge- PST and the cost of an automobile-- summary under Subsection 6(7) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(7) car standby charge is reduced for the sales tax reduction occurring where a trade-in allowance is provided on the car purchase Where a trade-in forms part of the consideration paid for a purchased automobile, the amount of GST/HST and provincial sales tax (“PST”) payable on the purchase may be reduced to reflect the trade-in. ...

What would be the consequences if the RRSP transferred the Co-op shares to the annuitant for consideration equalling the cost of the shares to the RRSP, so as to return the RRSP to it previous position? ...

21 July 2009 Internal T.I. 2009-0322591I7 F- Déduction des intérêts-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition replacement of note and capitalized interest by new note with increased amount did not constitute payment by novation of the old debt The taxpayer purchased assets from the vendor (apparently, a non-resident) in consideration for shares of the taxpayer and interest-bearing debt, that was evidenced by a note providing that unpaid interest could be added to the principal of the note. ...

In indicating that there generally was an increase to the ACB of their shares, the Directorate stated: [A] transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital …. ...

CRA responded: The arrangement … appears to be one of bartering whereby the PSB provides services to its client in exchange for the use of an automobile and possibly other consideration paid by the client. ...