Search - consideration

5 October 2012 APFF Roundtable, 2012-0454241C6 F- Double imposition-- summary under Section 325 Summary Under Tax Topics- Excise Tax Act- Section 325 double taxation from contemporaneous ITA/ETA assessments avoided by ITA assessment being 1st A, who is indebted to each of CRA and Revenue Quebec (ARQ) for $50,000, transfers $10,000 of property to A's spouse (B) for no consideration. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration S. 95(2)(c) which, insofar as relevant to the question of how it dovetails with s. 93.2, is essentially identical to s. 85.1(3). ...

8 October 2010 Roundtable, 2010-0373611C6 F- Certificat avant distribution-- summary under Subsection 159(3) Summary Under Tax Topics- Income Tax Act- Section 159- Subsection 159(3) directors of corporate trustee generally are generally not liable under s. 159(3) A trust, whose sole trustee is a corporation, acquired, as its only asset, a property valued at $50 million (the "Property") in consideration for the issuance of a note payable in the same amount, and then disposed of the Property and used the proceeds to repay the note. ...

In the 10th year, the corporation assigns the insurance policy without consideration to the shareholder, who pays the premium due for the 10th year and then receives a full refund of all premiums paid during the term of the policy. ...

Accordingly, the individual shareholder of Managementco transfers his shares of Managementco to Opco in consideration for shares of Opco and Managementco is wound-up into Opco. ...

Furthermore, Element E of the ACB requires consideration of policy loans repaid prior to the time of the ACB calculation. ...

If the facts show that the gain constitutes a portion of the consideration the consultant received for his or her services, the CRA feels that the gain must be treated as business income.... ...

., it was consideration for the disposition of the leasehold interest (used as a principal residence) that the tenant had acquired in 2013 and held since then to the time of the lease termination. ...

A transferred his shareholding of Opco 1 (wholly-owned by him) to a corporation (Opco 2) equally owned by him and his spouse in consideration for a note. ...

8 July 2020 CALU Roundtable Q. 7, 2020-0842251C6- Valuation of private company shares-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other special voting shares generally are not accorded value CRA confirmed a previous position that “provided that the owners of all the shares of the corporation act in a manner consistent with the assumption that no value attaches to the voting rights, and the rights are eventually extinguished for no consideration, the CRA will generally not attribute value to the rights,” so that, for example, “in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of an estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, the CRA generally accepts not to take into account any premium that could be attributable to such shares for the purposes of subsection 70(5).” ...