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Canco provided services for no consideration to LLC1. The Directorate concluded that Canco thereby was rendered a resident contributor to NRTrust (so that NRTrust was deemed to be a s. 94-resident trust) because s. 94(2)(f) deemed there to be a transfer of property to that trust, and it would be reasonable to view there as having been a resulting increase in the fair market value of the LLC1 shares. In the Directorate’s view, this result obtained even if s. 247(2) also applied to deem Canco to have received FMV consideration for its services. ...

15 January 2021 External T.I. 2020-0847781E5- CEWS- remuneration / SSUC- rémunération-- summary under Eligible Employee Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Eligible Employee non-cash taxable benefits are not “eligible remuneration” for CEWS purposes, but are “remuneration” for “eligible employee” purposes Q.1 Are taxable benefits taken into consideration in determining whether the 14 day remuneration condition is met and, if so, how is a particular portion thereof determined to be in respect of particular days in a qualifying period? ... Q.3 Is there is a difference between remuneration that has to be taken into consideration for the 14 day remuneration condition and the “eligible remuneration” paid to an employee to calculate the CEWS? ...

The estate then disposed of all its shares of Investments to Newco in consideration for Note2. ... Investments then transferred its stock market investments to four testamentary trusts created under X’s will (Trust1, Trust2, Trust3 and Trust4) in consideration for Trust-Note1, Trust-Note2, Trust-Note3 and Trust-Note4. ...

. … [W]here it can be determined … that the option is granted in consideration for services that are to be rendered after the time of grant and upon the fulfillment of a condition or contingency, the income should instead be recognized when the services are rendered, the amount is quantifiable and the rights are unrestricted. … [Here] the vesting of the option is linked to the completion of the long-term research project. As such, it may be difficult to conclude that the income is earned before the vesting date under the particular arrangement. … [G]enerally, it is at the time where the services have been rendered and the contingency has been fulfilled, that the FMV of the underlying share over the aggregate of the exercise price of the option should be included in income under subsection 9(1). … … Where the facts indicate that the incremental value represents part of the consideration received by the taxpayer for consulting services rendered, the incremental value should generally be treated as business income for purposes of the Act. ...

Fund LP transfers its Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new subsidiary LP (New LP) in consideration for the plain-vanilla units. ... The other former partners sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...

In order that Parent could get basis for having issued the share consideration, it was stated in a funding agreement to have issued such shares in consideration for the issuance to it by Merger Sub1 of common shares of Merger Sub1 – and CRA ruled that indeed those shares issued to Parent had a cost to it equal to the FMV of the shares issued by it in turn to the Target shareholders plus any related costs incurred by it. ...

At the same time as the subscription in 1, Trust 2 will transfer its Class A shares of Holdco to Newco 2 in consideration for Class D.2 non-voting common shares of Newco 2 on a s. 85(1) rollover basis. Concurrently with 1 and 2, Trust 1 will transfer the Class H shares of Holdco to Newco 2 in consideration for Class H.2 non-voting preferred shares of Newco 2 whose PUC will equal the ACB of the transferred shares. ...

4 January 2022 External T.I. 2015-0607531E5 F- Action admissible de petite entreprise-- summary under Subparagraph 110.6(14)(f)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) can apply to an amalgamation S. 110.6(14)(f)(i) provides that, for purposes of the requirement in s. 110.6(1)(b) that mooted qualified small business corporation shares ("QSBCSs") must not have not been owned during the 24 months preceding their disposition (the “determination time”) by anyone other than the disposing individual or a related person or partnership, such shares will be considered to have been so owned prior to their issuance by a “bad” owner unless they were issued as consideration for other shares (the “original shares”). ... X) exchanges his majority shareholding of Opco for shares of a new personal holding company Holdco) and then, around a year later, receives replacement shares of Amalco on an amalgamation of Holdco with Opco followed by a sale by him (and the minority shareholder) of their Amalco shares to a third party, CRA accepted that s. 110.6(14)(f)(i) applied on the amalgamation, i.e., that the Amalco shares could be regarded under the scheme of the Act as being “issued” in consideration for the shares of the relevant predecessor (Holdco). ...

2021 Ruling 2020-0847671R3 F- Transfert d'un immeuble-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no s. 15(1) benefit on property transfer to shareholders for its nominal appraised FMV if indeed such FMV was suppressed by the low-rent long-term leases to the shareholders Background A not-for profit corporation described in s. 149(1)(l) (the “Corporation”) governed by the CBCA acquired a building from a partnership (“SENC”), without assuming a mortgage on the building, in consideration for granting leases to the various apartments in the building and issuing common shares, allocated in proportion to the floor areas of their leased apartments. ... Rulings Including that the transfer to the Owner Shareholders would not result in a capital gain to the extent that the FMV of the property and the proceeds of disposition were equal to or less than the property’s ACB and that such transfer would l not give rise to any taxable benefit in the hands of the Owner Shareholders pursuant to ss. 15(1) and 246(1) to the extent that the FMV of the share of the real property so transferred to each of the Owner Shareholders was equal to or less than the FMV of the consideration therefor paid by such shareholder. ...

In the year immediately preceding that sale on January 1 of all the shares of Aco, Aco paid a dividend in kind of the policy to Trust X, so that the policy was deemed to be disposed of for the greatest of its ACB, CSV and the (nil) consideration received, or $150. ... Instead, s. 148(7) would deem the proceeds of disposition of the policy to the trust to be the FMV of the consideration received by the trust for the disposition, namely, the $250 note repayment. ...