Search - consideration

., the trust distributes to the four (4) children the net taxable capital gain, which is $250,000 each, in consideration for which each child will claim his or her capital gains exemption. ... We are unable to provide guidance on the operation GAAR because it requires the consideration of all of the relevant facts which we cannot assess in this context. ...

It should also be noted that where a person who holds an interest in a SBIT knew at the time of the issue of the interest, or at the time of contributing in respect of the interest, that a substantial portion of the consideration or contribution would not be invested in SBS's, and all or substantially all of the consideration or contribution would be returned within 24 months, then subsection 5104(4) of the Regulations would deem the trust to not be a SBIT. ...

As sole consideration for the transfer, Cco will issue to Lossco: (a) Cco Class A Preferred Shares with a redemption/retraction amount of $XXXXXXXXXX; and (b) Cco Common Shares with a fair market value not exceeding the difference between the fair market value of the Dco Common Shares transferred to Cco and the fair market value of the consideration described in subparagraph (a) of this paragraph. 3. ...

24 January 2006 External T.I. 2005-0157581E5- taxation of CPP death benefits Unedited CRA Tags 220 56(1)(a.1) Principal Issues: request for administrative relief Position: none available XXXXXXXXXX 2005-015758 Annemarie Humenuk January 24, 2006 Dear XXXXXXXXXX: Re: Taxation of CPP Death Benefits This is in reply to your letters of October 13, and November 3, 2005, in which you ask for fairness consideration in respect of the death benefit payable under section 71 of the Canada Pension Plan ("CPP death benefit") received by the Estate of the XXXXXXXXXX All statutory references in this letter (other than the reference above) are references to the provisions of the Income Tax Act, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"). ... In your letter, you request "tax fairness consideration". The fairness provisions described on the Canada Revenue Agency's website, http://www.cra-arc.gc.ca/agency/fairness/fair-prov-e.html, refer to the provisions in section 220 that were enacted in 1991 as part of the fairness package. ...

Going forward, as CRA gains experience with increased electronic data sources and filing requirements, consideration could be given to conducting a review to reduce or eliminate overlap and duplication where possible. ...

CALU Roundtable- May 2018 Question 3- Subsection 148(8)-Transfer of an insurance policy from a parent to child Background Subsection 148(8) provides for a rollover of a life insurance policy where an interest in the life insurance policy is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the life insured under the policy. ... CRA Response Subsection 148(8) of the Act provides that, if an interest of a policyholder in a life insurance policy (other than an annuity contract) is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of the disposition equal to the adjusted cost basis of the interest immediately before the transfer, and to have been acquired by the person who acquired the interest at a cost equal to those proceeds. ...

All of Usco2’s assets are used in the active business. 5) Forco is a corporation resident in the United States that is not related to Canco. 6) Forsub is a wholly-owned subsidiary of Forco resident in the United States. 7) Usco2 sells the beneficial ownership in all of its active business assets to Forsub for fair market value consideration but retains legal title thereto. 8) On the day following the transaction described in paragraph 7 above, Usco1 sells the shares of Usco2 to Forco for fair market value consideration. ...

Position: The consequences of a release or surrender of an income interest for no consideration are set out in paragraph 9 of IT-385R2. ... The reference in that paragraph to "validly" requires consideration of the terms of the trust indenture and the relevant provincial law. ...

In that regard, the PHSP involves (i) an undertaking by one person (ii) to indemnify another person (iii) for an agreed consideration (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain. ... Accordingly, the payment by the patient of the annual fee would not be a qualifying medical expense under paragraph 118.2(2)(a) of the Act, nor would it qualify as a "premium, contribution or other consideration" 118.2(2)(q) of the Act. ...

To the extent that the transfers result in a Holdco owing fractional interests in the marketable securities, the Holdcos may sell the fractional interests among themselves for fair market value consideration, however any such sales will be made within the parameters of paragraph 55(3.1)(c). As consideration for the transferred properties referred to above, each Holdco will: (a) assume one-third of the current accounts payable of XXXXXXXXXX, and one-third of the shareholder loans of XXXXXXXXXX; and (b) issue to XXXXXXXXXX Class XXXXXXXXXX Preference Shares of its capital stock having an aggregate redemption amount and fair market value equal to the amount by which the fair market value of the transferred properties received by it as a result of the transfers described herein exceeds the fair market value of the liabilities of XXXXXXXXXX assumed by it. ...