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4 April 1990 Income Tax Severed Letter 90M04438 F- Transfers for Inadequate Consideration Unedited CRA Tags 85(1)(e.2), 86(2), 87(4), 51(2), 55(2), 110.6(7)      24(1)      April 4, 1990      PART II Transfers for Inadequate Consideration {85(1)(e.2); 86(2); 87(4) and 51(2)} The corporate reorganization sections in the Income Tax Act contain provisions which impose "penalties" for transfers to or share exchanges with corporations where the value of the property given up exceeds the value of the property received, and "it is reasonable to regard any part of such excess as a benefit that the taxpayer desired to have conferred on a person related to the taxpayer. ...

7 November 1990 Income Tax Severed Letter- Loan guarantee from non-resident for no consideration Unedited CRA Tags 214(15)(a) QUESTION I 78 Loan Guarantee from Non-resident for no Consideration A Canadian corporation ("Canco") borrows funds from an arm's length lender (the "lender"). Canco's non-resident parent corporation (the "parent") guarantees the loan for no consideration. ... Since the parent did not receive consideration for its guarantee of the loan, the parent will not be deemed by paragraph 214(15)(a) of the Act to have been paid interest on the loan. ...

8 September 1988 Income Tax Severed Letter 5-6310- [Donations to Registered Charities in Consideration for an Annuity] J.D. ... In our view, the word "gift" has been interpreted as being a voluntary transfer of property without consideration and without conditions. ... A secondary consideration was the ease of administration of the position for both the charities involved and the Department. ...

It is our general view that the provisions of subsection 85(1) of the Act could apply where shares of one class of a corporation are transferred to the corporation for consideration consisting of shares of another class of the corporation. Our general view would not be affected by the fact that the consideration received by the transferring shareholder includes warrants issued by the corporation. ... Consequently, the fair market value of the warrants would constitute non-share consideration received by the transferor in the course of disposing of eligible property to a taxable Canadian corporation. ...

7 November 1991 Income Tax Severed Letter- Deductibility of Consideration Paid for Player Rights Unedited CRA Tags 9 Dear Sirs: Re: Deductibility of Consideration Paid for Player Rights This is in reply to your letter of XXX concerning the deductibility, for purposes of the Income Tax Act, of consideration paid for player rights in the following hypothetical situation: "A partnership (the "Partnership") will pay a fee to obtain membership in a professional sports league with all the privileges of membership, including a franchise for a team in a particular city, and the rights to select players with league experience from the present teams in the league and to priority drafting position in 1992 player drafts (such rights collectively referred to as the "Player Rights"). ...

29 November 1989 Income Tax Severed Letter RRRR138- Letters for consideration by another Revenue Canada employee Unedited CRA Tags none As recently discussed with Mr. ... Jolie of your office, we are forwarding for your consideration and reply the yellow file folder containing XXX letter of October 31, 1989 addressed to the Honourable Otto Jelinek. ...

7 July 1990 Income Tax Severed Letter- Tax consequences to a farmer of receipt of proceeds from granting right of access and easement to a vineyard and receipt of consideration for permanent damages to vineyard as result of underground gas pipeline constructed under right of way Unedited CRA Tags 14(1), 14(1)(a), 20(1)(b), 110.6(2) Dear Sirs: This will reply to your letter of June 7, 1990 requesting our views on the tax consequences to a Canadian farmer of the receipt of proceeds from the granting of a right of access and easement to his vineyard and the receipt of consideration for permanent damages to his vineyard as a result of an underground gas pipeline constructed under the right of way. ... Therefore the consideration received by him for the right of access and easement would be an amount described in subparagraph 14(5)(a)(iv). ...

24 September 1996 Income Tax Severed Letter 9613015- Gift — consideration Unedited CRA Tags 118.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Paragraph 3 of Interpretation Bulletin IT-110R2 states that a gift for income tax purposes, is a voluntary transfer of property without valuable consideration. ... No valuable consideration- no benefit of any kind- to the donor or to anyone designated by the donor may result from the payment. ...

7 August 1991 Income Tax Severed Letter- Fair Market Value of Shares Received as Consideration for the Shares Transferred to a Corporation Unedited CRA Tags none Dear Sirs: Re: Advance Income Tax Ruling XXX We are writing in response to your letter of July 15, 1991 wherein you requested our views XXX. ... Comments As stated in the reply to question 13 at the 1980 Revenue Canada Round Table, the Department is concerned with the fair market value of the shares received as consideration for the shares transferred to the corporation pursuant to subsection 85(1) of the Income Tax Act (Canada) (the “Act”). ...

7 May 1991 Income Tax Severed Letter- Dispositions- Absence of Consideration Unedited CRA Tags 54(c), 50(1)(b)(iii) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Facts XXX Issues XXX Our Comments Interpretation Bulletin IT-460, Dispositions- Absence of Consideration states in Paragraph 4 that "The following occurrences do not constitute a disposition (within the meaning of paragraph 54(c)) of a share of a corporation... ...