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The corporation no longer needs the policy on the executive’s retirement, and it transfers the policy to him for no consideration at a time when the particulars are: Death benefit $1,000,000 Cash surrender value $ 125,000 Adjusted cost basis $ 50,000 Fair market value $ 125,000 Without being queried on this issue, CRA stated: Although there are certain exceptions in the "advantage" definition, a benefit arising from the RCA holding a life insurance policy is not among them. ...

X 100 Class A shares for nominal consideration and also issues 100 discretionary dividend shares to Holdco. ...

5 October 2012 APFF Roundtable, 2012-0454061C6 F- Transfer of a Lossco to a related corporation-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) related but not affiliated transfer of Lossco shares to father's or brother's company Example 1 Son claims an ABIL under s. 50(1) with respect to his share investment in a wholly-owned corporation (Lossco), which had ceased active business operations in the year, and then transfers his shares of Lossco at the beginning of the following year to a corporation wholly-owned by his Father (Profitco) for consideration of $1, with Lossco then being wound-up into Profitco under s. 88(1). ...

5 October 2012 APFF Roundtable, 2012-0454061C6 F- Transfer of a Lossco to a related corporation-- summary under Subsection 88(1.1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1) lossco losses maintained on father-son or sibling transfers and s. 88(1.1) wind-up Example 1 Son claims an ABIL under s. 50(1) with respect to his share investment in a wholly-owned corporation (Lossco), which had ceased active business operations in the year, and then transfers his shares of Lossco at the beginning of the following year to a corporation wholly-owned by his Father (Profitco) for consideration of $1, with Lossco then being liquidated into Profitco under s. 88(1). ...

X to Trust, at a stipulated price and for consideration equal to its FMV, does not result in the income from the Property being attributed to Mr. ...

. … The expectations of a knowledgeable and prudent investor should be determined on the assumption that there would be no delay, postponement or default in the payment of dividends, that the dividends would be paid each year at a predetermined fixed or floating rate and that the proceeds to be received by the investor on the disposition of the share are the same amount the corporation received as consideration on the issue of the share. ...

Subsection 160(1) would not apply to any transfers of property where fair market value consideration is received in return. ...

11 June 2013 STEP Roundtable Q. 9, 2013-0480351C6- STEP CRA Roundtable Q9- June 2013-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) meaning of sale in Sommerer Respecting whether CRA accepted Sommerer, it stated that the decision stood: for the general proposition that where property is transferred to a trust by a beneficiary of the trust in return for consideration that constitutes a fair market value, subsection 75(2) will not apply to attribute income in respect of that property to that beneficiary. ...

Mr X sells all his shares of Corporation A to Corporation B in consideration for a promissory note, resulting in his receipt of a deemed dividend under s. 84.1(1)(b) that is less than the GRIP of B. ...

5 October 2012 APFF Roundtable, 2012-0454241C6 F- Double imposition-- summary under Subsection 160(2) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(2) ETA s. 325 assessment in same audit is issued after ITA s. 160 to avoid double tax/no priority accorded to ARQ 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. ...