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27 March 1994 Internal T.I. 9333227 - SHAREHOLDER BENEFIT -- summary under Subsection 15(1)

27 March 1994 Internal T.I. 9333227- SHAREHOLDER BENEFIT-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) Where a taxpayer has transferred property to a corporation pursuant to s. 85(1) and has received consideration in excess of the fair market value of the property transferred, s. 85(2.1) in its amended form will apply before subsection 84(1). Accordingly, to the extent that the excess consideration exceeds the paid-up capital of the shares received by the taxpayer on the transfer, such amount will no longer be taxed as a deemed dividend but will be taxed as a shareholder benefit under s. 15(1). ...

27 March 1994 Internal T.I. 9333227 - SHAREHOLDER BENEFIT -- summary under Subsection 85(2.1)

27 March 1994 Internal T.I. 9333227- SHAREHOLDER BENEFIT-- summary under Subsection 85(2.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(2.1) Where a taxpayer has transferred property to a corporation pursuant to s. 85(1) and has received consideration in excess of the fair market value of the property transferred, s. 85(2.1) in its amended form will operate to apply that provision prior to subsection 84(1). Accordingly, to the extent that the excess consideration exceeds the paid-capital of the shares received by the taxpayer on the transfer, such amount will no longer be taxed as a deemed dividend but will be taxed as a shareholder benefit under s. 15(1). ...

3 March 2004 Internal T.I. 2004-0061781I7 F - Engagement de non-concurrence -- summary under Exempt Receipts/Business

3 March 2004 Internal T.I. 2004-0061781I7 F- Engagement de non-concurrence-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Manrell inapplicable where recipient of non-compete carried on the related business In finding that consideration received by a corporation for a non-compete covenant given by it on the sale of one of its two businesses gave rise to an eligible capital amount, the Directorate indicated that Manrell and Fortino were inapplicable because there, unlike here, the two shareholders who received consideration for a non-compete covenant respecting the sale of their corporations “were not carrying on any business.” ...

2002 Ruling 2002-0160913 - INTEREST -- summary under Paragraph 20(1)(c)

In order to transfer interest expense from Holdco to the Opco business, Holdco transfers its common shares of Opco to a newly incorporated Canadian subsidiary ("Newco2") in consideration for a promissory note of Newco2 and for share consideration, and Newco2 and Opco then amalgamate. ...

2002 Ruling 2002-0177163 - Subsection 87(4) - S/H Rights Plan -- summary under Subsection 87(4)

2002 Ruling 2002-0177163- Subsection 87(4)- S/H Rights Plan-- summary under Subsection 87(4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(4) Rights under a shareholder rights plan of Parent received by shareholders of Target on a triangular amalgamation of Target, a subsidiary of Parent and Parent would not constitute "consideration" for purposes of s. 87(4) given that the rights were of little or no value and given that: "The Amalgamation Agreement will provide that the shares of Parent and Amalco... will be the sole consideration for the exchange. ...

2015 Ruling 2014-0541261R3 F - Post-Mortem Planning -- summary under Subsection 84(2)

" Holdco will redeem the Class B preferred shares held by Sister, Brother 1 and Brother 2, in consideration for a demand non-interest bearing note, with Holdco making eligible dividend designations. Holdco will transfer its GICs to Investmentco in consideration for Class B non-voting retractable preferred shares, with the sale agreement containing a price adjustment clause, and with a s. 85(1) election made. Holdco will redeem the Class B preferred shares which Newco acquired in 2, in consideration for a demand non-interest bearing note ("Note 2"), with Note 2 containing a price adjustment clause. ...

2015 Ruling 2015-0605901R3 F - Présomption de gain en capital -- summary under Paragraph 55(3.01)(g)

Holdco 1, Holdco 2, Holdco 3, Opco 3 and Holdco 4 incorporate Holdco and (following the incorporation of Realtyco by Holdco) transfer their shares of Opco to Holdco on a rollover basis under s. 85(1) in consideration for Class A common shares of Holdco. ... Holdco transfers its Class B shares of Opco to Realtyco on a s. 85(1) rollover basis in consideration for Class A common shares of Realtyco. ... Realtyco redeems the Class C shares held by Opco in consideration for Note 2. ...

Quebec (Agence du revenu) v. Services Environnementaux AES inc., 2013 DTC 5174 [at at 6466], 2013 SCC 65, [2013] 3 SCR 838 -- summary under Rectification & Rescission

in consideration for $720,000 to be satisfied by (a) a promissory note of $335,000 (corresponding to the ACB of her shares) and (b) the issuance of 385,000 Class C preferred shares with a redemption amount of $385,000. ... Archambeault's shares of Déchiquetage being converted on the amalgamation into common shares of JPF-2, and then they provided in the documents for the redemption of those common shares in consideration for the promissory note of $335,000 and the issuance of 385,000 preferred shares. ...

Jean Coutu Group (PJC) Inc. v. Canada (Attorney General), 2016 SCC 55, [2016] 2 SCR 670 -- summary under Rectification & Rescission

Canada (Attorney General), 2016 SCC 55, [2016] 2 S.C.R. 670-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification must give effect to common intention at time The taxpayer (“PJC Canada”), a Quebec corporation, implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. subsidiary (“PJC USA”), that overlooked foreign accrual property income considerations – so that interest generated to PJC USA on a loan that it made back to PJC Canada was included in PJC Canada’s income. ... Although…modifications to written documents expressing parties’ agreement can include the insertion of transactions, this is possible only where doing so would bridge the gap between the contracting parties’ common intention and the written expression thereof Turning to broader policy considerations, he stated (at paras 41-43): …[A]ccepting PJC Canada’s position…would… undermine one of the fundamental principles of our tax system: that tax consequences flow from the legal relationships or transactions established by taxpayers. … [A]lowing the amendment of the written documents … would amount to retroactive tax planning. ...

Canada v. Société des alcools du Québec, 2002 FCA 69 -- summary under Regulations/Statutory Delegation

He had to identify the factor most likely to achieve the objective established by Parliament, based on relevant considerations. The way in which alcoholic beverages were treated disregarded the considerations that were relevant in identifying the tax that had been paid on those goods, and is contrary to the purpose of the Act. ...

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