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30 October 2002 Internal T.I. 2002-0134077 F- ATTRIBUTION DES GAINS EN CAPITAL-- summary under Subsection 74.5(6) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(6) presence of indirect transfer through Holdcos for s. 74.5(1) purposes reinforced by s. 74.5(6) Two individuals transferred the shares they held of a particular company to their respective holding companies which, in turn, each disposed of a portion of those shares to the individuals’ respective spouses in consideration for non-interest-bearing notes. ...

. … [Furthermore] it seems reasonable … to conclude that Madame desired to confer a benefit on Monsieur since, as sole director of the Corporation, it was she who chose to set the redemption value of the Class D shares at an amount lower than the FMV of the Class A shares transferred in consideration. ...

The position of the taxpayer "that in order that 40(3.5)(c) applies, a share disposed of must first meet the three conditions under s. 40(3.3) applicable to capital property disposed of and for a period of 30 days after the disposition, before the deeming rule provided under s. 40(3.5)(c) can be taken into consideration" did not make sense. ...

LLC (“Sisterco LLC”) and the consideration paid, and also proposed a secondary adjustment under s. 247(12) on the basis that a resulting benefit conferred on Sisterco LLC was deemed to be a dividend that was paid by Canco that was subject to a Pt. ...

It did so by transferring that business to a newly-incorporated U.S. subsidiary (Splitco) in consideration for Splitco common shares, and then distributing those shares on the Original Shares (with the Original Shares ultimately being cancelled). ...

Furthermore, the application of the amended section 245 must be in accordance with the object, spirit and purpose of such provision and of the other provisions that are relied upon by the taxpayer as well as, ensure that economic substance receives proper consideration. ...

The second part of paragraph 248(5)(a) expands the scope of this concept in envisaging an indeterminate number of substitutions, establishing a link between the initial property under consideration and the property acquired in the final substitution. ... Parent transferred its undivided interest in the shares of Canco3, as well as the remainder shares of LLC2, to Publico in consideration for a note (5). ... Publico transferred such properties, in turn, to USCO1 in consideration for the issue of preferred shares (B Shares) (6). ...

27 October 2011 Internal T.I. 2010-0382161I7 F- CPN-144- remises et ristournes-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit purchase price rebates earned after purchase are income rather than inventory cost reduction In light of their treatment under International Accounting Standard (IAS) 2, "Inventories," and Emerging Issues Committee (EIC) Abstract EIC-144, "Accounting by a Customer (including a Reseller) for Certain Consideration Received from a Vendor," may volume rebates received or receivable by food wholesalers from suppliers be applied to reduce the cost of the purchased food inventory, or must they be included in income? ...

Holdco purchased the preferred shares for cancellation in consideration for the issuance of preferred shares denominated in Canadian dollars. ...

11 March 2014 Internal T.I. 2013-0506801I7- Salary and Wages, Part IV of the Regulations-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) no s. 8 deductions; payroll of PEs outside Canada included Respecting the application of the definition of "salary or wages" in s. 248(1), CRA stated that "subsection 402(3) of the Regulations contemplates only the salaries and wages paid by the corporation to the employees, which precludes consideration of the deductions available to an employee under section 8. ...