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Ceci étant, certaines considérations peuvent faire en sorte qu’il ne soit pas souhaitable de distribuer les biens de la fiducie immédiatement à un bénéficiaire qui est une personne physique. ...

The Supreme Court of Canada in Crown Forest (footnote 1) observed that the OECD Model “has world-wide recognition as a basic document of reference in the negotiation, application and interpretation of multilateral or bilateral tax conventions” and was “of high persuasive value in terms of defining the parameters” of the tax treaty under consideration in that case. ...

Section 84.1 achieves its purposes by: (1) reducing the paid-up capital of the shares of the subject corporation, which reduces the ability to return paid-up capital of the purchaser corporation as the excess would be taxed as a dividend, and (2) deeming the individual shareholder to have received a dividend where the purchaser corporation pays non-share consideration for the shares of the subject corporation that exceeds the greater of the paid-up capital and the “hard ACB” of the particular shares transferred. ...

Such proposals have not been taken into consideration in this response. ...

To benefit from interest rates that are lower than the prevailing market rates, a penalty is paid to the financial institution in consideration of a reduced interest rate payable on the loan. ...

In the past, Opco disposed of a Class 10 depreciable property, selling it to its parent company (Manageco) for the nominal consideration of $1, the fair market value (hereinafter "FMV") of the property at the time. ...

The Integrated Team will take into consideration whether the taxpayer has an effective TCF in place. ...

Example 4: Shareholders of DCco transfer shares of DCco having an aggregate PUC of $10,000 and an ACB of $1,000 to TCco in consideration for shares of TCco. ...

X subscribes to new common shares of the capital stock of the non-SBC for nominal consideration. ...

In some instances, a note was issued by the corporation to the estate as consideration for the redemption of a portion of its shares held by the estate; and some of the proposed transactions contemplated the corporation liquidating some of its assets in order to repay this note before the Pipeline Note is repaid. ...