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On January 1, 2009, the US employee was granted stock options by Canco in consideration for his duties of employment performed for USCo and, following the exercise of the options on December 31, 2010, USCo paid Canco a sum equal to the in-the-money value of the options at the time of such exercise ($20,000). ...

However, …taking into consideration the flexible tracing approach mandated… in Ludco …as well as the comments in paragraph 1.38 of the Folio …Amalco would be entitled to allocate the entire amount of the Assumed Debt to its assets other than the FA shares. ...

. … In addition … a likelihood of a particular production generating revenues other than those provided for in the original broadcast contract, for example, from the sale of DVDs, the awarding of contracts for broadcasting on the Internet, on specialty channels or in territories not covered by the original broadcast contract, can also be taken into consideration in determining whether the costs related to a production should be considered as capital expenditures in respect of depreciable property. … [W]here the broadcast contract covers a period of several years, under which the broadcaster has the right to broadcast the production several times during that period, this would be an argument to support that the costs associated with the production provide a lasting benefit to the producer. ...

-dollar purchase price, of which a specified portion was paid in Corporation C shares (the parent of Corporation B) as stated consideration for a specific number of Corporation A shares determined in accordance with the sale Agreement, and the balance was paid in cash. ...

Respecting Scenario 2: [A]s is apparent from Duha, the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement. ...

The Partnership subsequently transferred all of its assets, including the shares of the Creditor Affiliate, to a newly formed wholly-owned U.S. subsidiary of Partnership (the “Debtor Affiliate”), the consideration for which included the Debtor Affiliate assuming the Partnership’s liability to repay the Loan and to pay the accrued but unpaid interest thereon (the “Accrued Interest”) to the Creditor Affiliate. ...

17 December 2003 Internal T.I. 2003-0047727 F- Right of Use-Deemed Trust-- summary under Subsection 105(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(1) no s. 105(1) benefit from personal use of personal-use property of a trust An individual (“Sister”), who had been experiencing financial difficulties, disposed of her home, part of which she had been renting out, to Opco, which was a subsidiary of a corporation (“Holdco”) controlled and partly owned by her sister ("X") (with X’s children as common shareholders) for fair market value consideration. ...

It subsequently sold its Lossco shares to a profitable wholly-owned subsidiary ("Profitco") for nominal cash consideration, with Lossco then being wound-up into Profitco under s. 88(1) so that Profitco could then access Lossco's non-capital losses pursuant to s. 88(1.1). ...

Profit- Futures/Forwards/Hedges equity swap was to hedge the risk under a capital borrowing, so that loss on closing out the swap was on capital account In connection with its monetization of the shares of a corporation, the taxpayer transferred the shares of that corporation to a Newco ("Corporation2") in consideration for shares of Corporation2, entered into an equity swap with a financial intermediary with respect to the shares of Corporation2 under which it agreed to pay the appreciation in the value of the shares of Société2 above a ceiling level, and the counterparty agreed to pay the depreciation in value of the shares of Corporation2 below a floor level, and the taxpayer borrowed money from another financial institution. ...

Subsequently to the transactions considered in 2017-0735771I7, ACo transferred its shares of BCo to DCo for consideration including shares of the capital stock of DCo pursuant to subsection 85.1(3) of the Act. ...