Search - consideration

2005 Ruling 2005-0123631R3- Thin Capitalization Rules-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) GAAR will apply to prevent what otherwise would be the avoidance of the thin capitalization rule when debts owing by a Canadian corporation to a non-resident affiliated corporation (Finco) are transferred by the Finco to a partnership organized by that Canadian subsidiary and a Canadian affiliate in consideration for the issuance of interest-bearing debt by the partnership to the Finco. ...

21 December 1995 Ruling 940411 [tenant pays for improvements on lease termination]-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) tenant pays for improvements on lease termination An amount payable by a tenant on the termination of a lease, equal to the amortized value of leasehold improvements, would not be considered to be subject to s. 182 but, instead, would be regarded as consideration for a supply by the tenant of such improvements. ...

Accordingly, the fees generated by it were consideration for taxable services rather than being financial services under paragraph (1). ...

2013 Ruling 2012-0472721R3- Inter-vivos share transfer under 73(4) and (4.1)-- summary under Subsection 73(4.1) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(4.1) sale for low-rate promissory notes Rulings that, subject to s. 69(11), s. 73(4.1)(a)(i) and s. 73(4.1)(b) applied to the transfer of shares of Farmco by Individuals 1 and 2 to a child of each in consideration for promissory notes bearing interest at the prescribed rate and to be forgiven by the estate of Individual 1 or 2, as the case may be, in the event of death. ...

2014 Ruling 2013-0505431R3- XXXXXXXXXX-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) s. 97(2) applicable to contribution (no equity consideration) In connection with an extensive reorganization, Pubco will transfer its undivided interest in a royalty to a partnership (Partnership D) mostly owned by it as a contribution to its capital, with a s. 97(2) election being made. ...

2015 Ruling 2014-0552871R3- Split-Up Butterfly-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) post-butterfly sale of distributed shares by one TC to the other In connection with the butterfly split-up of DC equally between the family holding companies (Shareholder1 and Shareholder2) for two unrelated families, the shares of Subco2, which might be a significant subsidiary of DC, are split 50-50 between the two transferee corporations (TC1 and TC2) on the butterfly, then TC1 sells its shares of Subco2 to TC1 for FMV consideration. ...

2010 Ruling 2009-0330901R3- Reorganization of XXXXXXXXXX-- summary under Paragraph B(a) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Forgiven Amount- Element B- Paragraph B(a) no forgiven amount on transfer by unit trust to its parent of debt owing by parent A unit trust (Trust 1) purchases for cancellation most of its units held by its parent (Subco) in consideration for the transfer to Subco of debt owing by Subco. ...

2004 Ruling 2004-0088541R3- Loss utilization-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Loss utilization transactions in a related group of companies under which Profitco transfers its promissory note of a wholly-owned subsidiary of Profitco ("Subco") to a sister company with losses ("Lossco") in consideration for Class A preferred shares of Lossco, and Profitco then transfers the Class A preferred shares to Subco in exchange for Class AA preferred shares of Subco. ...

15 May 2012 GST/HST Ruling 142436- Implementation of Cost Sharing Arrangement-- summary under Agency Summary Under Tax Topics- General Concepts- Agency parent bearing payroll and source deductions for itself and subs A parent corporation, which for source deduction purposes was treated as the employer of employees, was accepted for GST purposes as incurring part of the payroll as agent for subsidiaries, so that reimbursement payments received by it from the subsidiaries were not consideration for taxable supplies. ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement-- summary under Subsection 6204(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(3) where pursuant to an arrangement agreement that is implemented under a plan of arrangement, employee stock options previously granted by the "Target" are transferred by the employees to Target in exchange for cash amounts equal to their in-the-money value before the acquisition pursuant to the agreement and plan by the purchaser of 100% of the shares of Target for cash consideration, such purchaser will not be a "specified person" at the time the options are so transferred. ...