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Le fait que deux contrats ne soient pas souscrits simultanément est un élément qui est pris en considération. ...

CLHIA Roundtable – May 2013 Question 5- Section 116 Withholding: Related Party Transfers Where a life insurance policy in Canada is transferred from a non-resident to a related party for no consideration, subsection 116(5.1) provides that the proceeds of disposition are deemed to be the fair market value of the policy. ...

The court in BBM agreed that these were reasonable considerations for the purposes of applying the tax exemption. ...

(footnote 3), reconnaît qu'une transaction peut être annulée avec effet rétroactif lorsque les parties réalisent la transaction sur la base d'une erreur sur la considération principale. ...

In contemplation of the sale of the FA common shares and repayment of the debt, Canco acquires preferred shares of FA for nominal consideration. ...

Position: Under consideration. Reasons: An excess Part XIII tax payment arises when the income is remitted to or received in Singapore and is required to be included in the computation of income under Singapore laws. ...

Une nouvelle société (" Nouco ") est créée et Opco souscrit à 100 actions de catégorie A de Nouco pour une considération totale de 100 $. ...

However, pursuant to subparagraph 191(4)(d)(i) of the ITA, the deemed dividend which arises from the redemption of a taxable preferred share which was issued for consideration that included another taxable preferred share no longer benefits from this exclusion. ...

Comments Under the proposed version of subsection 88(3) included in the draft legislation on foreign affiliates issued on February 27, 2004, paragraph 88(3)(c) deems the taxpayer's proceeds of disposition of the shares of the foreign affiliate to include an amount equal to the total of all amounts each of which is the cost to the taxpayer of a distributed property received by the taxpayer as a consideration for the disposition of the shares. ...

CRA's Response Subsection 148(8) of the ITA stipulates that if the interest of a policyholder in a life insurance policy, other than an annuity contract, is transferred to the policyholder's child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of disposition equal to the ACB to the policyholder of the interest immediately before the transfer, and to have been acquired by the person who acquired the interest for a cost equal to those proceeds. ...