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Before the end of Newco's taxation year, Newco will purchase for cancellation the Newco preferred shares held by Transferor in consideration for a demand note. After the end of Newco's first fiscal period, Transferor will purchase for cancellation the Class A shares and Class D shares of its capital stock held by Newco in consideration for a demand note. ...

Under the ruled-upon transactions: The Holdco shareholders transfer a portion of their Holdco common shares on a s. 85(1) rollover basis to Opco in consideration for preferred shares of Opco bearing a cumulative dividend which tracks the payment of the earnout payments described below (presumably giving rise to a significant increase in Opco under s. 55(3)(a)(ii) or (v)); The key employee immediately purchases those Holdco common shares from Opco (perhaps also described in s. 55(3)(a)(ii) or (v)) in consideration for five annual instalments, with each annual instalment based on the most recent year’s earnings (plus, in the case of the first instalment, the opening shareholders’ equity), with adjustments to the purchase price on any IPO or business acquisition; and Each instalment payment after its receipt by Opco is dividended (as the "Earnout Tracking Dividends") by Opco to the Holdco shareholders on the tracking preferred shares. ...

After referencing the ss. 6(1) and 7 rules, CRA stated: Based on the facts, the Registration fees that the [Organization] collects from individuals who attend a particular […] conference are consideration for a supply of IPP in respect of which the Canadian rights can only be used in the province in which the […] conference takes place. ...

22 September 2011 Ruling Case No. 129475-- summary under Section 9 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part III- Section 9 A for-profit corporation (the "Corporation") provides a service for fees to the families of non-resident minor children in consideration for arranging for them to study at a Canadian school district, stay at a Canadian home and participate in eight recreational activities to be arranged by the Corporation. ...

22 September 2011 Ruling Case No. 129475-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply A for-profit corporation (the "Corporation") provides a service for fees to the families of non-resident minor children in consideration for arranging for them to study at a Canadian school district, stay at a Canadian home and participate in eight recreational activities to be arranged by the Corporation. ...

15 October 2004 Ruling RITS 52698-- summary under Paragraph 142(1)(c) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(1)- Paragraph 142(1)(c) situs of supply where resort points seized In connection with rulings on the consequences of the seizure by creditors and resale by them of resort points, the Directorate noted that the portion of sold resort points that was considered to be supplied in Canada was determined by prorating the consideration payable by a recipient of resort points based on the extent to which the resort points represented a right to use real property situated in Canada. ...

13 December 2000 Ruling 31635-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) fees incurred to enhance shareholder value ineligible Respecting the fee paid by a corporation to a financial advisor regarding strategic alternatives for the enhancement of shareholder value including a potential sale of its shares or assets, the CCRA stated: From the letter of engagement, the costs do not meet the above criteria to be entitled to ITCs as they were not acquired for the purpose of making taxable supplies for consideration in the course of that endeavour. ...

Although no rulings were given on the paid-up capital of the LLCs, the description of the "Shares" of the Delaware LLC ("LLC2") to be contained in the LLC Agreement- and similarly for California- stated: "Capital" of Shares is the aggregate of all amounts paid to LLC 2 and the monetary value at the time of contribution of property contributed to LLC 2 (in each case including amounts paid or contributed prior to USco 2's conversion to LLC 2) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 2 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 2 Agreement. ...

The provision of such guarantees by the taxpayer for no consideration would not, in and by themselves, disqualify the taxpayer from satisfying the requirements of s. 132(6)(b). ...

2004 Ruling 2003-0053981R3- XXXXXXXXXX-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) elimination of MFT corporate sub through creation of MFC and 132.2 merger A mutual fund trust (the "Fund") subscribes for Class A redeemable retractable shares of a newly-incorporated subsidiary ("MFC") and distributes the Class A shares to its unitholders as a return of capital with MFC then electing to be a public corporation, Fund transfers its common shares and notes of a subsidiary ("Holdco") which in turn holds limited partnership units in a partnership to MFC in consideration for redeemable retractable Class B shares of MFC, MFC and Holdco amalgamate, the amalgamated corporation ("Amalco MFC") merges into the Fund as described in s. 132 and the Fund transfers its partnership units to a subsidiary trust. ...