Search - consideration

Non-share consideration means all the consideration received by the vendor other than shares of the transferee corporation or a right to receive such shares. ... Original Agreed Amount $100(a) Fair market value of property transferred 80(c) Consideration: Fair market value of non-share consideration received $149 Fair market value of share consideration received 1 Total Consideration $150(b) The agreed amount would be deemed by paragraph 85(1)(b) to be $149 except that paragraph 85(1)(c) (which deems the agreed amount to be $80) takes precedence over paragraph 85(1)(b). ... Cost to Transferor of Consideration Received from the Corporation ¶ 21. ...

Non-share consideration means all the consideration received by the vendor other than shares of the transferee corporation or a right to receive such shares. ... Original Agreed Amount $100(a) Fair market value of property transferred 80(c) Consideration: Fair market value of non-share consideration received $149 Fair market value of share consideration received 1 Total Consideration $150(b) The agreed amount would be deemed by paragraph 85(1)(b) to be $149 except that paragraph 85(1)(c) (which deems the agreed amount to be $80) takes precedence over paragraph 85(1)(b). ... Cost to Transferor of Consideration Received from the Corporation ¶ 21. ...

ARCHIVED- Excise and GST/HST News- No. 94 From: Canada Revenue Agency Table of Contents Economic Action Plan 2014 Act, No. 2 Draft GST/HST Policy Statement released for public comment Form RC4616- Election for nil consideration under section 156 of the Excise Tax Act Regulations Amending Various GST/HST Regulations Reporting and filing options for certain excise duty licensees Prescribed rates of interest What’s new in publications Enquiries Economic Action Plan 2014 Act, No. 2 On October 10, 2014 the Minister of Finance tabled a Notice of Ways and Means Motion to implement tax provisions in Economic Action Plan 2014. ... Please send comments on this draft policy statement by February, 28, 2015, to the following address: Director Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate Canada Revenue Agency 14th floor, Place de Ville, Tower A 320 Queen Street Ottawa, ON K1A 0L5 Form RC4616- Election for nil consideration under section 156 of the Excise Tax Act The election under section 156 permits corporations resident in Canada and Canadian partnerships that are registrants engaged exclusively in commercial activities and that are members of the same qualifying group, to jointly elect to treat taxable supplies (with certain exceptions) between them as having been made for no consideration. Effective January 1, 2015, an election (or revocation of an election) must be made jointly by a particular specified member of a qualifying group and another specified member of the same group by completing and filing Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes which is replacing Form GST25. ...

Courtesy and consideration You have the right to be treated with courtesy; respect, and consideration. ...

Courtesy and consideration You have the right to be treated with courtesy; respect, and consideration. ...

Courtesy and consideration You have the right to be treated with courtesy; respect, and consideration. ...

ARCHIVED- Excise and GST/HST News- No. 95 From: Canada Revenue Agency Table of Contents Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration No offset of GST/HST and QST amounts for selected listed financial institutions with a consolidated filing election Service standard for responding to written requests for GST/HST rulings and interpretations Online services for GST/HST accounts Representatives – request or delete authorizations online Prescribed rates of interest What’s new in publications Enquiries Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration As discussed in the Excise and GST/HST News – N o 91 and N o 94, section 156 of the Excise Tax Act permits corporations resident in Canada and Canadian partnerships that are: registrants engaged exclusively in commercial activities; and specified members of the same qualifying group to jointly elect to treat taxable supplies (with certain exceptions) made between them as having been made for no consideration. ... These parties must complete and file Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes. ...

Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Cost Considerations ¶ 4. The process of converting debt to distress preferred shares usually involves complicated banking, tax and corporate law considerations, resulting in significant legal and other costs. ... The main reason for this is that, taking into consideration the various business corporations acts, this structure affords creditors the most security with respect to the distress preferred shares received in substitution for their debt. ...

Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Cost Considerations ¶ 4. The process of converting debt to distress preferred shares usually involves complicated banking, tax and corporate law considerations, resulting in significant legal and other costs. ... The main reason for this is that, taking into consideration the various business corporations acts, this structure affords creditors the most security with respect to the distress preferred shares received in substitution for their debt. ...

If the holder of the rights uses them to run the corporation in conflict with the common shareholders or seeks or is offered consideration for them, it would be difficult for the CRA to ignore this evidence of value. ... Cost of Property Acquired from a Shareholder for No Consideration Question The CRA previously stated that where property is transferred to a corporation by a shareholder for no consideration, the corporation will not have any cost base in the property. In a 2007 ruling, [Footnote 29] the CRA ruled that the corporation obtained tax basis in cash transferred by a shareholder to the corporation for no consideration. ...