Search - consideration

Donor ($200,000), (ii) the FMV of the consideration given for the interest ($0) and (iii) the ACB of the interest to Mr. ...

Respecting the PPT’s application to CIVs issues, CRA will give consideration to matters such as other articles in the particular covered treaty, e.g., para. 7(a) of the Canada-France Treaty, any relevant competent authority agreement, e.g., the Canada-Netherlands agreement regarding closed funds for mutual account and previous rulings, e.g., on Switzerland contractual investment funds and Ireland common contractual funds. ...

A wholly-owned subsidiary of Canco 1 (Canco 2) will agree to repay the Loan on behalf of Canco 1 at maturity and in consideration for that undertaking, Canco 1 will issue a Canadian dollar denominated note (the “Canco 1 Note”), with an equivalent Canadian-dollar principal, to Canco 2. ...

CRA stated: Subsection 148(8) … provides that, if an interest of a policyholder in a life insurance policy (other than an annuity contract) is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of the disposition equal to the adjusted cost basis of the interest immediately before the transfer, and to have been acquired … at a cost equal to those proceeds. ...

CCRA indicated the following consequences of the transfer of the policy by the corporation to the individual for no consideration: Pursuant to s. 148(1), the corporation was required to include $75,000 in income, being the excess of the deemed proceeds of disposition under s. 148(7) over the policy ACB ($125,000- $50,000). ...

. … If a taxpayer is motivated by tax considerations when he or she enters into a business or property venture, this will not detract from the venture's commercial nature or characterization as a source of income under the Act. ...

27 November 2018 CTF Roundtable Q. 5, 2018-0780041C6- GAAR on PUC reduction-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) no challenge of a reduction of PUC of shares of DC held by TC before redemption Shareholders of DCco transfer shares of DCco having an aggregate PUC of $10,000 and an ACB of $1,000 and a FMV higher than $10,000 to TCco in consideration for shares of TCco and as part of a distribution of property of DCco to TCco. ...

14 May 2019 CLHIA Roundtable Q. 2, 2019-0799051C6- 2019 CLHIA Roundtable- 148(7) questions-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) s. 6(1)(a) applied to transfer of life insurance policy to employee at an undervalue, notwithstanding the application of s. 148(7) As a result of an arm's length employee B no longer being considered to be a key employee, her employer (Corporation A) transfers its “key person” permanent life insurance policy on her life to her for nominal consideration. ...

14 May 2019 CLHIA Roundtable Q. 2, 2019-0799051C6- 2019 CLHIA Roundtable- 148(7) questions-- summary under Paragraph 148(7)(b) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(7)- Paragraph 148(7)(b) cost of policy gratuitously transferred to arm's length employee determined under s. 148(7)(b) rather than s. 52(1) As a result of employee B no longer being considered to be a key employee, her employer (Corporation A) transfers its “key person” permanent life insurance policy on her life to her for nominal consideration. ...

It was a question of fact whether the husband and wife could be considered to satisfy the excluded business test for a particular year or continue to meet such test thereafter, as consideration must be given to the ongoing nature and labour requirements of the corporation’s business. ...