Search - consideration

Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares. ... In other words, expenses which are CEE by virtue of subparagraphs (i) to (iii.1) would be disqualified from treatment as CEE if the expenses were incurred in consideration for shares of a corporation. ... Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares because such CEE referred to in subparagraph (v) is identical to that in (iv). ...

There is no requirement that the consideration given to a resource expenditures. The consideration for which the Shares are issued will be valued at it fair market value at that time. ... If the value of the property is $1,000, the consideration given for the flow-through shore agreement with the issuing corporation would renounce resource expenditures to the taxpayer in an amount equal to $1,000. ...

The consideration to be received by XXX According to the schedule provided in your request, the consideration to be received is significantly less than the current fair market value of the property being transferred. ... This paragraph operates to deny the capital gains deduction to an individual where a capital gain has been realized from the disposition of property as part of a series of transactions in which any property is acquired by a corporation for consideration that does not approximate its fair market vallue at the time of acquisition. It should be noted that the draft legislation to implement the income tax reform measures proposes to amend this provision to apply in situations where the consideration received is significantly less than the fair market value of the property at the time of acquisition. ...

Corporation B agrees to issue as consideration, an agreed number of its common shares and to enter into the appropriate agreements, file the prescribed forms, etc. so that the shares will be flow-through shares for purposes of paragraph 66(15)(d.1) of the Act. 5. ... There is no requirement that the consideration given to a resource corporation for the Shares be property used to incur resource expenditures. The consideration for which the Shares are issued will be valued at its fair market value at that time. ...

Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares. ... In other words, expenses which are CEE by virtue of subparagraphs (i) to (iii.1) would be disqualified from treatment as CEE if the expenses were incurred in consideration for shares of a corporation. ... Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares because such CEE referred to in subparagraph (v) is identical to that in (iv). ...

The consideration to be received by XXXX According to the schedule provided in your request, the consideration to be received is significantly less than the current fair market value of the property being transferred. ... This paragraph operates to deny the capital gains deduction to an individual where a capital gain has been realized from the disposition of property as part of a series of transactions in which any property is acquired by a corporation for consideration that does not approximate its fair market value at the time of acquisition. It should be noted that the draft legislation to implement the income tax reform measures proposes to amend this provision to apply in situations where the consideration received is significantly less than the fair market value of the property at the time of acquisition. ...

It is your opinion that paragraph 110.6(7)(b) of the Act would not apply because consideration referred to in the paragraph is not the amount agreed upon (the "elected amount") referred to in subsection 85(1) of the Act. ... We agree that the term "consideration" as referred to in paragraph 110.6(7)(b) of the Act does not mean the elected amount referred to in subsection 85(1) of the Act. ... However, if the total consideration received by a transferor is significantly less than the fair market value of the property transferred in a transaction governed by section 85 of the Act, paragraph 85(1)(e.2) of the Act would apply in addition to paragraph 110.6(7)(b) of the Act. ...

During a reorganization of capita1 by XXXX the corporation redeems all of its common shares and in return issues new common shares and certain non-share consideration. ... In this case, as the fair market value of the non-share consideration received exceeds the ACB of to XXXX of his old shares of XXXX the ACB of his new shares will be nil and the proceeds of disposition of his old shares will be equal to the fair market value of the non-share consideration received. The resulting capital gain should be computed in Canadian dollars and the relative U.S. dollar amounts should be converted to Canadian dollars at the rate of exchange in effect at the time XXXX acquired the old shares to determine his ACB and at the time XXXX received the non-share consideration on the recapitalization of XXXX to determine proceeds of disposition. ...

Conference- September 1991 Question 48- Dividends and Section 160 Question Under subparagraph 160(1)(e)(i) of the Act, a non-arm's length transferee of property may be liable jointly with the transferor and is limited to the amount by which the value of the transferred property exceeds the value of any consideration given for the property. ... Does Revenue Canada agree that for the purposes of subparagraph 160(1)(e)(i) of the Act (a) the declaration of the dividend does not constitute a transfer of property, and (b) the extinguishment of the corporate debt on payment of the dividend constitutes valuable consideration given for the dividend? ... The purpose of this paragraph to prevent a person with substantial income tax liability from defeating the claims made on him by transferring his property to any non-arm's length party at less than fair market value consideration. ...

Thus, ACo sells the property to BCo at its fair market value of $1,000,000 and the consideration received is: a mortgage of $200,000 assumed, preferred shares $800,000, total: $1,000,000. In addition, on the sale, BCo agrees to assume a $500,000 mortgage in consideration for the issue of a demand note by ACo to BCo for $500,000. ... Can BCo continue to deduct interest on the portion of the $500,000 mortgage which corresponds to the debt assumed in consideration of the demand note by ACo to BCo? ...