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Accordingly, we have not had the opportunity to give full consideration to whether the above position should apply for purposes of that provision. ...

7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F- Critical Illness Insurance-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) benefit on gratuitous transfer of critical illness policy by corporation to its shareholder CRA noted respecting the transfer for no consideration of a critical illness insurance policy by Opco (which was the policyholder, beneficiary and had paid all the premiums) to its shareholder (so that the shareholder became the holder and beneficiary) to Holdco, that although no capital gain would arise on the transfer to Opco, under s. 15(1) “the value of the benefit could correspond to the FMV of the policy.” ...

8 October 2010 Roundtable, 2010-0373471C6 F- Actions fictives-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement phantom share analysis is fact sensitive As consideration for bringing new employees to a Canadian corporation (“Opco”), Serviceco is issued phantom shares of Opco which generate cash payments equaling the dividends paid on corresponding common shares of Opco and which, on a change of control, are convertible into common shares of Opco. ...

-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as absolute payment for the transfer of s. 28 inventory In finding that a cash-basis farmer realized income on the transfer of inventory for a promissory note, CRA stated: Since the promissory note was accepted as consideration for the transfer of the inventory, and given that none of the documents provide any remedy for non-payment, it appears that payment could only be enforced under the terms of the promissory note. ...

10 October 2003 Roundtable, 2003-0035665 F- TRANSFER D'UNE POLICE D'ASSURANCE-VIE-- summary under Subsection 148(7) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(7) transfer to shareholder at policy’s FMV is not a “distribution” A corporation transfers a policy on the life of an arm’s length shareholder for consideration equal to the policy’s fair market value, which exceeds its cash surrender value. ...

In broad terms, a deemed trust established under those provisions ceases to apply to property of a tax debtor when the tax debtor disposes of the property in the normal course of business for FMV consideration to an arm's length bona fide purchaser. ...

[W]e have not had the opportunity to give full consideration to whether the above position should apply for purposes of [s. 104(4)(a).] ...

28 November 2010 CTF Annual Roundtable, 2010-0384341C6- Flow-through Shares-- summary under Flow-Through Share Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Flow-Through Share flow-through unit Respecting whether CEE can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share, CRA stated: CEE can be renounced only in respect of the portion of the subscription price allocated to a warrant which represents a right to acquire a share that would be a flow-through share [as] pursuant to paragraph (b) of … "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share…. ...

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

10 October 2014 APFF Roundtable, 2014-0538621C6 F- Disposition en contrepartie de 1$-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) treatment of transfer for nominal consideration as "gift" turns on Quebec law Does CRA consider, similarly to Revenu Québec, that a transfer of an immovable for $1 can be a gift? ...