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REASONS: Inducement Costs represents rights relating to leases in respect of the property transferred in the butterfly and the consideration paid for these rights should be deductible by the transferee corporations (See Ruling 3-980098). ... As consideration for the assignment of the benefit of the Inducement Costs, each of XXXXXXXXXX /Bco and Newco will assume a portion of the Liabilities with a principal amount equal to the amount of the benefit of the Inducement Costs assigned to XXXXXXXXXX /Bco or Newco, as the case may be. ...

To the best of your knowledge and that of the XXXXXXXXXX none of the issues referred to herein are currently under objection or consideration by a Tax Services Office or Taxation Centre in connection with a return already filed. ... Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...

A SAR generally permits an employee to dispose of the employee's rights under the option and in return receive as consideration, an amount in the form of cash or shares, equivalent to the increase in value of the option over the period it was held by the employee. ... In particular, the terms of the EIP would not simply provide a means for an employee to dispose of the employee's rights under the option and in return receive in consideration an amount, in the form of cash or shares, equivalent to the increase in value of the option. ...

In the situation you described, the total amount paid by the general public as consideration for the placement of insurance is usually comprised of a premium payable to an insurer for coverage under the policy, and a commission payable to an insurance broker as consideration for the placement of insurance. ...

Reasons: The Bitcoin is received by the "miner" as consideration for services rendered. ... In our view, Bitcoin received by a miner to validate transactions is consideration for services rendered by the miner. ...

3 April 2020 External T.I. 2020-0836991E5- Eligible property and stock options Unedited CRA Tags 85(1), 85(1.1), 54(b) Principal Issues: Can "in the money" stock options, not subject to the rules of section 7, be transferred into the issuing corporation on a tax deferred basis receiving share consideration instead of exercising the options? ... Generally speaking, the rules in section 85 allow for a tax-deferred transfer of “eligible property” by a taxpayer to a taxable Canadian corporation where consideration for that transferred property includes shares of that corporation and the other conditions set out therein are met. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the Trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...