Search - consideration

In consideration for the early termination of the lease, the new owner paid $15,000 to the tenant. ...

In consideration for the early termination of the lease, the new owner paid $15,000 to the tenant. 2007-0254721R3 confirmed that an amount received for the termination of a lease can come within the principal residence exemption. ...

A transfers all the shares of Opco 1 to Opco 2 (which is owned 50-50 by him and his spouse) in consideration for a note. 2002-0128955 indicated that a corporation is not entitled to a dividend refund respecting a dividend it is deemed to have paid under s. 84.1(1)(b). ...

. … … The determination of when a corporation is wound up for the purposes of subsections 88(1) and 88(2) requires consideration of all facts and circumstances relevant to a particular situation. ...

Prior to maturity, and when the adjusted cost base of her interest (of $120,000) is less than its fair market of her interest of $140,000 (based on the fair market value of the investments in the segregated fund), she transfers her interest to a taxable Canadian corporation in consideration only for common shares. ...

CRA responded: Canada’s position is that any assessment that relies on a domestic anti-avoidance rule will be eligible for MAP consideration- but Canada will simply present the Canadian position relying on that anti-avoidance rule to the other Competent Authority for potential relief by the other country. ...

CRA indicated that s. 86.1(1)(a) did not accommodate an exchange (here, a disposition of US Pubco shares in consideration for Spinco shares) so that this was not an eligible distribution contemplated by s. 86.1. ...

In the final version of its response, CRA added the statement: At this time, the CRA is in the process of consulting internal stakeholders to evaluate and potentially develop a position on this issue, while giving consideration to the impacts on other foreign reporting forms ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 8, 2021-0899701C6 F- Post-mortem planning- Pipeline-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) a pipeline transaction can use an existing corporation rather than a Newco In order to implement pipeline planning, the estate of an individual ("Estate") generally incorporates a new corporation ("Newco") to which it sells shares of a private corporation ("Target"), with or without a tax rollover, in consideration for shares of Newco (the "Shares") or a note issued by Newco ("Note").Newco will remain in existence for at least one year before being merged with Target to form Amalco, whose assets are gradually used to redeem the Shares or Note. ...

The Queen-- summary under Employee Benefit Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Employee Benefit Plan trust providing for distributions of employer shares on a fully discretionary basis is not governed by s. 7 When asked to comment on the McNeeley decision, CRA stated: When contemplating the establishment of a trust which will acquire securities of an employer to be held for the benefit of employees, consideration of the EBP rules is advised. ...