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2015 Ruling 2014-0552871R3- Split-Up Butterfly-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) post-butterfly sale of distributed shares by one TC to the other In connection with the butterfly split-up of DC equally between the family holding companies (Shareholder1 and Shareholder2) for two unrelated families, the shares of Subco2, which might be a significant subsidiary of DC, are split 50-50 between the two transferee corporations (TC1 and TC2) on the butterfly, then TC1 sells its shares of Subco2 to TC1 for FMV consideration. ...

2010 Ruling 2009-0330901R3- Reorganization of XXXXXXXXXX-- summary under Paragraph B(a) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Forgiven Amount- Element B- Paragraph B(a) no forgiven amount on transfer by unit trust to its parent of debt owing by parent A unit trust (Trust 1) purchases for cancellation most of its units held by its parent (Subco) in consideration for the transfer to Subco of debt owing by Subco. ...

22 March 2005 External T.I. 2004-0098591E5 F- Application de l'alinéa 212(9)d) proposé-- summary under Paragraph 212(9)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(9)- Paragraph 212(9)(d) extension to provincial regulatory authority under review CRA indicated that the exemption as then worded did not apply if a provincial rather than federal authority was the party to the reinsurance indenture – but this matter was under consideration by Finance. ...

27 April 1998 External T.I. 9800145- non-competion agreements, client lists-- summary under Eligible Capital Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Eligible Capital Property A lump-sum payment received by the individual shareholder of a corporation upon a sale by that corporation of one of its business divisions and in consideration for a non-compete covenant given by the individual to the purchaser would be regarded as a capital gain arising on a disposition of "property" (the right of the individual to compete). ...

27 April 1998 External T.I. 9800145- non-competion agreements, client lists-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A lump-sum payment received by the individual shareholder of a corporation upon a sale by that corporation of one of its business divisions and in consideration for a non-compete covenant given by the individual to the purchaser would be regarded as a capital gain arising on a disposition of "property" (the right of the individual to compete). ...

27 April 1998 External T.I. 9800145- non-competion agreements, client lists-- summary under Capital Property Summary Under Tax Topics- Income Tax Act- Section 54- Capital Property A lump-sum payment received by the individual shareholder of a corporation upon a sale by that corporation of one of its business divisions and in consideration for a non-compete covenant given by the individual to the purchaser would be regarded as a capital gain arising on a disposition of "property" (the right of the individual to compete). ...

., the voluntary transfer of property (usually cash) by a donor to a registered charity with no consideration or benefit accruing to the donor or to anyone designated by the donor as a result of the transfer. ...

14 June 1994 External T.I. 9405845- TRUST PROPERTY ACQUIRED BY MORTGAGE-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) S.75(2) would not apply where a trust acquires a property from an arm's length vendor (who is not a trustee or beneficiary of the trust) in consideration for a vendor take-back mortgage which restricts the ability of the trust to sell the property during the one-year term of the mortgage without the consent of the vendor. ...

25 October 1994 External T.I. 9414095- TRANSFER OF SHARES OF FOREIGN AFFILIATE (HAA 6363)-- summary under Subsection 85.1(4) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(4) S.85.1(4) will not apply where Canco, which owns 100% of USco, transfers its shares of USco for fair market value consideration to a U.S. holding company ("Holdco") that also is a foreign affiliate of Canco, and Holdco then issues common shares to the public and has some of its shares sold by Canco to the public. ...

11 July 1995 Internal T.I. 9505997- EXTENDED WARRANTY-- summary under Subsection 18(9) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9) A client, who purchases an extended warranty on an asset that will be used for business purposes, will be required to apply s. 18(9) "where the set amount may reasonably be regarded as having been incurred as consideration for services to be rendered or for insurance in respect of a period, after the end of the year". ...