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CRA Response To our knowledge, your question has not previously been submitted for our consideration. ...

CRA Response In our opinion, a transaction on the open market by which a bond held by an individual is acquired, entitling the individual to receive proceeds in consideration, is generally a transaction that constitutes a disposition according to paragraph a) of the definition of "disposition" provided in subsection 248(1) of the Income Tax Act 2. ...

In the situation where the shareholder pays a reasonable fee to the corporation as consideration for the granting of the Guarantee, the Guarantee would not, in and by itself, give rise to a benefit. ...

The following transactions will be undertaken in year 2: Canco 2 will agree to repay the Loan on behalf of Canco 1 at maturity and as consideration for that undertaking, Canco 1 will issue a Canadian dollar denominated note (the “Canco 1 Note”) payable to Canco 2. ...

In some of these circumstances, consideration can be given to whether it may be better for taxpayers to determine whether the amount is excluded from the TOSI because it is a reasonable return of the individual based on the factors applicable in the circumstances. ...

Furthermore, the same analysis has to take into consideration the possible application of any of provisions in paragraphs 251(2)(b) and (c) of the Act. ...

This is something that may warrant further review so you might consider referring the matter to the local T.S.O. for consideration on audit. ...

Department’s Position The determination of how the foreign affiliate provisions apply to the money lending activities of a financing affiliate is a complex subject, requiring an in-depth understanding of the arrangements under consideration. ...

Réponse du ministère du Revenu Le bulletin d’interprétation IT-169 existe depuis longtemps (daté du 6 août 1974) et ne semble pas prendre en considération tous les types de clauses d’ajustement du prix ni toutes les situations où des clauses d’ajustement du prix sont maintenant habituellement utilisées. ...

As consideration for such loan, the borrower agrees to deliver its product of the same sort, the same in quantity and quality with what is borrowed, to the lender at a specific location and time. ...