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Administrative relief in this regard would require further consideration and consultation with various areas in the CRA. ...

Therefore, a net capital loss may be applied to a particular taxation year that is not open for reassessment if the request to amend the income tax return of the particular year to take into consideration the net capital loss is made within 10 calendar years after the end of the particular taxation year. 2023 CRA STEP Roundtable – June 20, 2023 Question 2. ...

Essentiellement, l’examen de tous les faits et circonstances entourant une situation bien précise doivent être pris en considération pour déterminer, d’un point de vue pratique et commercial, ce que les paiements en question visaient à accomplir. ...

In our view, a power of attorney under which a designated attorney exercises the voting rights of the controlling shareholder of a corporation as a consequence of the incapacity of the shareholder (who continues to be the legal and beneficial owner of the shares), would not constitute an external document that is to be taken into consideration in determining de jure control of the corporation. ...

À cette fin, le sous-alinéa 129(4)a)(i) L.I.R. de la définition d’IMRTDND repose sur un taux implicite d’impôt fédéral de 38 2/3 % applicable au RPE, sans prendre en considération le CIE. ...

.: assets used, property, liabilities or obligations, considerations received, revenue, income or loss, expenses or expenditures, businesses, activities, accounts, amounts, risks of loss and opportunities for gain or profit, outputs from businesses, proceeds from the issue of an obligation or the settlement of a debt, fair market values, time periods, duties, uses, members, benefits, and terms and conditions of shares). ...

Interpretation The shares of the subsidiaries issued in consideration for the property comprising businesses A and B are deemed by section 54.2 of the Act to be capital property of Canco. ... ROUND TABLE ON FEDERAL TAXATION APFF- 1994 ANNUAL MEETING Question 32 Interest Bearing Note Issued on Redemption of Shares A corporation redeems its shares for cancellation and issues in consideration an interest bearing note. ... The Queen (94 DTC 1100) ("Dale"), counsel for the Department appeared to hold that a rollover would be allowable inasmuch as the shares in consideration were issued before the end of the taxation year in which the transfer was made. ...

Whenever a transaction is reviewed by an auditor the value or FMV will be an audit consideration. ... Under existing legislation, consideration may be given to waiving interest in those instances where an individual is experiencing financial hardship and has no ability to pay the liability in full. ... The GAAR has been recommended for consideration in 26 of these cases. ...

X wants to transfer the policy to its wholly-owned corporation for no consideration. ...

Furthermore, to the extent that the property were to be distributed to a person, who is not dealing at arm's length with the corporation or trust, that person can be held liable under subsection 160(1) for the lesser of the tax payable by the corporation or trust and the amount by which the fair market value of the property exceeds the consideration given for the property. ...