Search - consideration

3 October 2011 External T.I. 2011-0421341E5- Paragraphs 55(3.1)(c) or (d)-- summary under Paragraph 55(3.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(c) before a distribution made in the course of a butterfly reorganization, Opco sells real estate used in operating its business (and representing more than 10% of the value of the business) to a non-related person for fair market value consideration consisting solely of cash. ...

19 December 2013 Internal T.I. 2013-0490751I7- Adjustment to a taxpayer`s CDA-- summary under Subsection 247(8) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(8) s. 247(2) trumps s. 69(1) The taxpayer, which was a private corporation, disposed of eligible capital property to a non-arm's-length non-resident sister company ("SisterCo") within the same multinational group in consideration for a promissory note. ...

16 June 2014 STEP Roundtable, 2014-0523061C6- Trust audit issues-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) settlor taking back undervalued freeze shares 2010-036630117 concerned the sole trustee and capital beneficiary of a trust (the taxpayer) who, had transferred property to the trust by accepting undervalued freeze shares as consideration when growth shares were issued to the trust. ...

19 December 2013 Internal T.I. 2013-0490751I7- Adjustment to a taxpayer`s CDA-- summary under Capital Dividend Account Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account s. 247(2) increase to ecp proceeds increased CDA on transaction effective date The taxpayer, which was a private corporation, disposed of eligible capital property to a non-arm's-length non-resident sister company ("SisterCo") within the same multinational group in consideration for a promissory note. ...

Accordingly, we have not had the opportunity to give full consideration to whether the above position should apply for purposes of that provision. ...

8 August 2014 External T.I. 2014-0524951E5- Debt forgiveness; liability on dissolution-- summary under Paragraph 80(2)(a) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(a) meaning of "settle" Before going on to note that the debt parking rules in ss. 80.01(6) and (8) would in any event deem the debt to be forgiven, CRA noted that in the circumstances there might also be a settlement of the debt for nil consideration on more general principles, and quoted a statement in Carma Developers Ltd. v. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by written instruments. ...

CRA stated: [A] cost-plus plan under which the administrator agrees to reimburse the sole employee-shareholder, his or her spouse, and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...

2014 Ruling 2013-0513211R3- Butterfly Transaction-- summary under Subsection 186(1) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1) split-up CCPC butterfly was structured to avoid Part IV circularity In a butterfly reorganization for the split-up of DC into three TCs, the Part Iv tax circularity problem is addressed by having DC transfer its properties to respective new Subcos of each TC, so that no s. 186(1)(b) Part IV tax is generated on the redemption of the prefs received by DC as consideration. ...

20 February 2013 External T.I. 2012-0473051E5 F- Frais de gestion versés à un conjoint-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 determining reasonableness of spousal management fee entails a “comparison to an amount paid for similar services according to industry standards” In the course of a general discussion of fees paid by the taxpayer for management services of the taxpayer’s spouse, CRA stated: The determination of the reasonableness of an amount for purposes of section 67 includes a consideration, among other things, of the nature and extent of the services actually provided by your spouse and their comparison to an amount paid for similar services according to industry standards. ...