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It would seem that such a decision should not be affected by income tax considerations. ... Any specific concern that you may have with respect to the tax policy behind subparagraph 251(5)(b)(i) and paragraph 256(1.4)(a) of the Act should be submitted to the Department of Finance for consideration. ...

15 August 2018 Internal T.I. 2018-0749931I7- Subsections 87(1), (1.1) and (4) Unedited CRA Tags Subsections 87(1), (1.1) and (4) Principal Issues: Whether the position described in paragraph 1.74 of the Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations (that a shareholder's aggregate ACB of its shares of a predecessor corporation, that are cancelled for no consideration on a horizontal short-form amalgamation, will be added to the cost of the shares of the amalgamated corporation, that are deemed to have been received by the shareholder on the amalgamation pursuant to subsection 87(4)) (the “Folio Position”) is technically correct? ... However, paragraph 1.74 of the Folio states that: Where shares of a predecessor corporation are cancelled for no consideration pursuant to a short-form horizontal amalgamation, the adjusted cost base of such cancelled shares to the shareholder will be added to the cost of the common shares of the new corporation which are deemed to have been received by the shareholder on the amalgamation under subsection 87(1.1). ...

The second position had been adopted by the Department even though on a strict interpretation of the "mid-amble" of paragraph 55(3)(b) (which will be reflected in proposed paragraph 55(3.1)(a)), it could reasonably be concluded that property becomes property of a corporation in contemplation of a butterfly when it acquires a partnership interest as consideration for the transfer of property to the partnership and then butterflies the interest to its shareholders. ... Where, in contemplation of a butterfly, a corporation transfers property to a partnership in consideration for a partnership interest, the acquisition of the partnership interest will come within the prohibition in proposed paragraph 55(3.1)(a). ...

Zion Assistant Director (613) 957-8953 Enquiries and Adjustments Attention: John Brady, T1 Processing 963203 Clergyman's Residence Deduction Subsection 8(1)(c) of the Act XXXXXXXXXX We are forwarding for your consideration and reply the attached letter from XXXXXXXXXX is requesting a review of an adjustment which disallowed the clergyman's residence deduction claimed by XXXXXXXXXX on his XXXXXXXXXX income tax return. ... As none of the terms under consideration are defined by the Act, Justice MacKay in his judgement outlined the history and intent of 8(1)(c) of the Act. ...

Another case we have been asked to consider is the situation where a donor is provided with an article (advantage) in consideration for a pledge to make donations over a number of years. ... If you encounter such a situation, we recommend that the case be referred to Rulings for further consideration. ...

Therefore, this time should not be taken into consideration in determining what percentage of employment duties are performed on a reserve for purposes of applying the Guidelines. ... Accordingly, for purposes of determining whether the Taxpayer's employment income (Base Salary, Stand-by Wages or Overtime Wages) should be exempt under one of the Guidelines, stand-by time should not be taken into consideration in calculating the percentage of employment duties performed on or off a reserve. ...

The particular situation is that the corporate taxpayer assumed liability to pay the principal and interest owing on a mortgage on the shareholder's personal residence, and, in consideration, part of an earlier non-interest bearing loan owing by the corporate taxpayer to the shareholder (which resulted from the transfer- in a prior year- of public shares from the shareholder to the corporate taxpayer) was forgiven by the shareholder. ... While the corporate taxpayer did acquire shares of public corporations in an earlier transaction and as consideration issued corporate indebtedness to its shareholder, we are not aware of any evidence that there was any connection between the subsequent assumption by the corporate taxpayer of its shareholder's mortgage and the acquisition of any property, including the public shares. ...

In the situation under consideration, a corporation redeems certain of its preferred shares and, as consideration for the redemption, assumes a bank loan owed by the redeeming shareholder. ...

Reasons: The Bitcoin is received by the "miner" as consideration for services rendered. ... In our view, Bitcoin received by a miner to validate transactions is consideration for services rendered by the miner. ...

Quoi qu'étant un important facteur d'appréciation, la superficie d'un élément d'actif utilisé directement dans une entreprise active n'est pas le seul critère devant être pris en considération.  Par exemple, la portion de la J.V.M. de l'élément d'actif qui est directement utilisé dans l'entreprise active devra également être prise en considération.  ...