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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. ...

Contents Application Summary Discussion and Interpretation Separate returns (¶ 1) Credits and deductions allowed Deductions in computing taxable income (¶s 2, 3) Non-refundable tax credits (¶s 4-8) Credits and deductions not allowed Deductions in computing net income (¶ 9) Deductions in computing taxable income (¶ 10) Tax credits (¶s 11-13) Other considerations (¶s 14-16) Explanation of Changes Application This bulletin replaces and cancels Interpretation Bulletin IT-326R2 dated February 2, 1990. ... " Other considerations ¶ 14. Pursuant to subsection 110.4(5), the forward averaging amount brought into income under subsection 110.4(2) cannot be reported in any of the separate returns filed as "another person. ...

Contents Application Summary Discussion and Interpretation Separate returns (¶ 1) Credits and deductions allowed Deductions in computing taxable income (¶s 2, 3) Non-refundable tax credits (¶s 4-8) Credits and deductions not allowed Deductions in computing net income (¶ 9) Deductions in computing taxable income (¶ 10) Tax credits (¶s 11-13) Other considerations (¶s 14-16) Explanation of Changes Application This bulletin replaces and cancels Interpretation Bulletin IT-326R2 dated February 2, 1990. ... " Other considerations ¶ 14. Pursuant to subsection 110.4(5), the forward averaging amount brought into income under subsection 110.4(2) cannot be reported in any of the separate returns filed as "another person. ...

Contents Application Summary Discussion and Interpretation Separate returns (¶ 1) Credits and deductions allowed Deductions in computing taxable income (¶s 2, 3) Non-refundable tax credits (¶s 4-8) Credits and deductions not allowed Deductions in computing net income (¶ 9) Deductions in computing taxable income (¶ 10) Tax credits (¶s 11-13) Other considerations (¶s 14-16) Explanation of Changes Application This bulletin replaces and cancels Interpretation Bulletin IT-326R2 dated February 2, 1990. ... " Other considerations ¶ 14. Pursuant to subsection 110.4(5), the forward averaging amount brought into income under subsection 110.4(2) cannot be reported in any of the separate returns filed as "another person. ...

Contents Application Summary Discussion and Interpretation General Considerations (¶s 1-2) Source of the Assistance (¶ 3) Reduction of the Cost of Capital Property Depreciable property (¶ 4) Non-depreciable capital property (¶ 5) Assistance provided in respect of eligible capital expenditures (¶ 6) Amounts Included in Income Under Paragraph 12(1)(x) Application of paragraph 12(1)(x) (¶ 7) Exceptions to the paragraph 12(1)(x) requirement (¶ 8) Prescribed amounts (¶ 9) Election to reduce the cost of capital property (¶s 10-13) Election to reduce the amount of an outlay or expense (¶s 14-15) Forgivable loans and guarantees (¶ 16) Tax credits and deductions from tax (¶ 17) Refunds (¶ 18) Partnerships and Trusts (¶ 19) Assistance Provided in Respect of Resource Property (¶ 20) Investment Tax Credit (¶ 21) Goods and Services Tax (¶ 22) Inducements to Medical Practitioners (¶ 23) Assistance from a Foreign Government (¶ 24) Natural Disasters (¶ 25) Repayments of Assistance General (¶ 26) Repayments of assistance in respect of eligible capital expenditures (¶ 27) Repayments of assistance in respect of non-depreciable capital property (¶ 28) Repayments of assistance in respect of depreciable property (¶ 29) Repayments of assistance after amalgamation (¶ 30) Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-273R dated January 19, 1981, its Special Release dated December 31, 1981, and IT-182 dated October 28, 1974. ... Discussion and Interpretation General Considerations ¶ 1. A taxpayer carrying on a business or earning income from property may receive some form of financial assistance from a government source as an inducement (e.g., measures to increase employment, measures to reduce production of certain inventory such as fish or produce), as a result of some governmental action other than expropriation (such as an order for the destruction of certain capital assets or inventory of the taxpayer, e.g., animals suffering from disease), or in respect of an income or property loss caused by a disaster (such as a flood, frost or explosion). ... Although consideration should also be given to the nature of the functions performed by the entity, a public authority is generally an entity which: (a) has a duty to the public; (b) is subject to a significant degree of governmental control; and (c) uses its profits for the benefit of the public. ...

Contents Application Summary Discussion and Interpretation General Considerations (¶s 1-2) Source of the Assistance (¶ 3) Reduction of the Cost of Capital Property Depreciable property (¶ 4) Non-depreciable capital property (¶ 5) Assistance provided in respect of eligible capital expenditures (¶ 6) Amounts Included in Income Under Paragraph 12(1)(x) Application of paragraph 12(1)(x) (¶ 7) Exceptions to the paragraph 12(1)(x) requirement (¶ 8) Prescribed amounts (¶ 9) Election to reduce the cost of capital property (¶s 10-13) Election to reduce the amount of an outlay or expense (¶s 14-15) Forgivable loans and guarantees (¶ 16) Tax credits and deductions from tax (¶ 17) Refunds (¶ 18) Partnerships and Trusts (¶ 19) Assistance Provided in Respect of Resource Property (¶ 20) Investment Tax Credit (¶ 21) Goods and Services Tax (¶ 22) Inducements to Medical Practitioners (¶ 23) Assistance from a Foreign Government (¶ 24) Natural Disasters (¶ 25) Repayments of Assistance General (¶ 26) Repayments of assistance in respect of eligible capital expenditures (¶ 27) Repayments of assistance in respect of non-depreciable capital property (¶ 28) Repayments of assistance in respect of depreciable property (¶ 29) Repayments of assistance after amalgamation (¶ 30) Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-273R dated January 19, 1981, its Special Release dated December 31, 1981, and IT-182 dated October 28, 1974. ... Discussion and Interpretation General Considerations ¶ 1. A taxpayer carrying on a business or earning income from property may receive some form of financial assistance from a government source as an inducement (e.g., measures to increase employment, measures to reduce production of certain inventory such as fish or produce), as a result of some governmental action other than expropriation (such as an order for the destruction of certain capital assets or inventory of the taxpayer, e.g., animals suffering from disease), or in respect of an income or property loss caused by a disaster (such as a flood, frost or explosion). ... Although consideration should also be given to the nature of the functions performed by the entity, a public authority is generally an entity which: (a) has a duty to the public; (b) is subject to a significant degree of governmental control; and (c) uses its profits for the benefit of the public. ...

Contents Application Summary Discussion and Interpretation General (¶s 1-2) Taxable dividends paid (¶s 3-6) Refundable dividend tax on hand (¶ 7) Refundable portion of Part I tax (¶s 8-9) Canadian and foreign investment income (¶s 10-19) Other considerations (¶s 20-22) Dividend refund rate Refundable dividend tax on hand Part I tax addition to RDTOH Definitions Aggregate investment income Eligible portion Foreign investment income Income or loss Refundable tax on CCPC's investment income Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-243R3 dated May 21, 1985, and the Special Release to IT-243R3 dated December 30, 1987. ... Other considerations ¶ 20. When determining the required tax instalments for a taxation year under section 157, paragraph 157(3)(b) allows each instalment to be reduced by one-twelfth of the dividend refund for that taxation year. ...

Contents Application Summary Discussion and Interpretation General (¶s 1-2) Taxable dividends paid (¶s 3-6) Refundable dividend tax on hand (¶ 7) Refundable portion of Part I tax (¶s 8-9) Canadian and foreign investment income (¶s 10-19) Other considerations (¶s 20-22) Dividend refund rate Refundable dividend tax on hand Part I tax addition to RDTOH Definitions Aggregate investment income Eligible portion Foreign investment income Income or loss Refundable tax on CCPC's investment income Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-243R3 dated May 21, 1985, and the Special Release to IT-243R3 dated December 30, 1987. ... Other considerations ¶ 20. When determining the required tax instalments for a taxation year under section 157, paragraph 157(3)(b) allows each instalment to be reduced by one-twelfth of the dividend refund for that taxation year. ...

Consideration is defined in the Act to include any amount payable by operation of law. ... As such, it is not a prescribed tax and is therefore included in the value of the consideration for the supply of vapour products in BC. ...

At the direction of X, Xco sells a piece of land for consideration that is less than fair market value in favour of Y, the child of X. ... Finally, the adjusted cost base of the piece of land to Y would, technically, be equal to the consideration he or she paid to Xco. See the current version of IT-405, Inadequate Considerations – Acquisitions and Dispositions, for additional discussions on the application of subsection 69(1). ...