Search - consideration

(June 1990 Access Letter, ¶1250)-- summary under Subsection 18(9) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9) Where an up-front fee is paid by a bank to another financial institution in respect of an interest-rate cap, no deduction may be made in the year of payment in respect of the portion of the fee which may be viewed as consideration for services to be rendered after the end of the year. ...

21 December 1995 Ruling 940411 [tenant pays for improvements on lease termination]-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) tenant pays for improvements on lease termination An amount payable by a tenant on the termination of a lease, equal to the amortized value of leasehold improvements, would not be considered to be subject to s. 182 but, instead, would be regarded as consideration for a supply by the tenant of such improvements. ...

"6363-1 Foreign Affiliate Deemed Active Business Income")-- summary under Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Affiliate A Wyoming limited liability corporation that indirectly was owned 50% by each of two Canadian corporations dealing at arm's length with each other would be a foreign affiliate of the Canadian corporation under consideration, with the result that s. 95(2)(a)(i) would apply to certain interest income earned by the limited liability corporation. ...

26 March 1992 External T.I. 5-913338-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Where a holding company assumes all of the debt associated with a property acquired by it from its subsidiary, interest on that debt will be deductible provided the property is used by the holding company for the purpose of earning income, even though for purposes of an s. 85(1) election, a substantial portion of that debt was assumed as consideration for a promissory note of the subsidiary rather than as payment for the transferred property. ...

26 March 1992 External T.I. 5-913338-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) Where a holding company assumes all of the debt associated with a property acquired by it from its subsidiary, interest on that debt will be deductible provided the property is used by the holding company for the purpose of earning income, even though for purposes of an s. 85(1) election, a substantial portion of that debt was assumed as consideration for a promissory note of the subsidiary rather than as payment for the transferred property. ...

5 July 1990 TI AC59710-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note is given in consideration for services, the acceptance of the note would be considered to be an amount received under s. 12(1)(a) where the note has been accepted as absolute payment for the services, whereas if the note has been accepted as conditional payment, s. 12(1)(a) will apply only when actual payments are made on the note assuming the related services have not yet been performed at that time. ...

Accordingly, the fees generated by it were consideration for taxable services rather than being financial services under paragraph (1). ...

2013 Ruling 2012-0472721R3- Inter-vivos share transfer under 73(4) and (4.1)-- summary under Subsection 73(4.1) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(4.1) sale for low-rate promissory notes Rulings that, subject to s. 69(11), s. 73(4.1)(a)(i) and s. 73(4.1)(b) applied to the transfer of shares of Farmco by Individuals 1 and 2 to a child of each in consideration for promissory notes bearing interest at the prescribed rate and to be forgiven by the estate of Individual 1 or 2, as the case may be, in the event of death. ...

2014 Ruling 2013-0505431R3- XXXXXXXXXX-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) s. 97(2) applicable to contribution (no equity consideration) In connection with an extensive reorganization, Pubco will transfer its undivided interest in a royalty to a partnership (Partnership D) mostly owned by it as a contribution to its capital, with a s. 97(2) election being made. ...

22 March 2016 Internal T.I. 2013-0506561I7- Property acquired on a return of capital-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base FMV cost of contributed or distributed property CRA considered that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value. ...