Search - consideration

16 August 1995 External T.I. 9521235- 6363-1 DEEMED ACTIVE BUSINESS INCOME-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) S.95(2)(a)(i) would apply to interest income earned by a foreign affiliate of Canco from financing purchases by arm's length non-resident customers of products sold by a related non-resident marketing corporation that purchased products manufactured in Canada by persons related to Canco for fair market value consideration. ...

30 April 2003 External T.I. 2002-0156045- Debt assumed as part/distribution from trust-- summary under Personal Trust Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Personal Trust The assumption of debt of a trust by the beneficiary would not be considered to entail an acquisition of the beneficial interest in the trust for consideration payable to the trust and, accordingly, would not by itself cause the trust to lose its status as a personal trust. ...

12 November 2003 External T.I. 2002-0121835- 85(1)- Holdbacks Payable-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) Where a contractor transferred its construction contract to a corporate purchaser, the amount previously withheld by the contractor as a holdback in respect of amounts otherwise payable to its subcontractor would represent part of the non-share consideration received by the contractor given that the liability in respect of these holdbacks would be assumed by the transferee corporation. ...

2004 Ruling 2004-0088541R3- Loss utilization-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Loss utilization transactions in a related group of companies under which Profitco transfers its promissory note of a wholly-owned subsidiary of Profitco ("Subco") to a sister company with losses ("Lossco") in consideration for Class A preferred shares of Lossco, and Profitco then transfers the Class A preferred shares to Subco in exchange for Class AA preferred shares of Subco. ...

12 April 1999 Income Tax Severed Letter 9812726- ARTICLE XXI CANADA-U.S. (4125-U5-100-21)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Before any consideration could be given to allowing an exemption for investment income paid to a U.S. master trust, the trust would be required to provide documentation that will clearly explain how it acted in trust for, or as agent for, the ultimate beneficial owners, the identity and residency of each beneficial owner, and the details of how the income was distributed to them. ...

15 May 2012 GST/HST Ruling 142436- Implementation of Cost Sharing Arrangement-- summary under Agency Summary Under Tax Topics- General Concepts- Agency parent bearing payroll and source deductions for itself and subs A parent corporation, which for source deduction purposes was treated as the employer of employees, was accepted for GST purposes as incurring part of the payroll as agent for subsidiaries, so that reimbursement payments received by it from the subsidiaries were not consideration for taxable supplies. ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement-- summary under Subsection 6204(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(3) where pursuant to an arrangement agreement that is implemented under a plan of arrangement, employee stock options previously granted by the "Target" are transferred by the employees to Target in exchange for cash amounts equal to their in-the-money value before the acquisition pursuant to the agreement and plan by the purchaser of 100% of the shares of Target for cash consideration, such purchaser will not be a "specified person" at the time the options are so transferred. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) realization and distribution of target MFT gain After the acquisition of a mutual fund trust (the "Fund") by Bidco, the Fund sells all its assets, including an interest in a limited partnership, to Bidco in consideration for the assumption of liabilities and a note of Bidco. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) In connection with the winding-up of an income fund (the "Fund") after the acquisition of all its units, the Fund disposes of its assets (principally, limited partnership units) to the acquiring corporation ("Bidco") in consideration for a note of Bidco, and then distributes the note to Bidco in satisfaction of a capital distribution and capital gains distribution declared by the Fund so that the note is extinguished as a matter of law. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 80(5) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(5) In connection with the winding-up of an income fund (the "Fund") after the acquisition of all its units, the Fund disposes of its assets (principally, limited partnership units) to the acquiring corporation ("Bidco") in consideration for a note of Bidco, and then distributes the note to Bidco in satisfaction of a capital distribution and capital gains distribution declared by the Fund so that the note is extinguished as a matter of law. ...