Search - consideration

27 January 2014 External T.I. 2013-0504191E5 F- RRSP, qualified investment-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (a) annuitant's free use of property of corporation held by RRSP is an advantage An RRSP annuitant uses, for no consideration, property of a corporation of which the RRSP holds shares. ...

2 April 2013 External T.I. 2013-0478221E5 F- CIAPH- acquisition pour une somme nominale-- summary under Subsection 118.05(3) Summary Under Tax Topics- Income Tax Act- Section 118.05- Subsection 118.05(3) purchase for nominal consideration still generates the credit Can the first-time home buyers' tax credit ("HBTC") be claimed where the taxpayer buys a house for the sum of a dollar? ...

6 October 2014 External T.I. 2014-0543751E5 F- Rollover of a part of an interest in a partnership-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) fractional partnership interest qualifies as eligible property X, who wished to dispose of half of interest (which is capital property) in a partnership to a taxable Canadian corporation in consideration for shares. ...

A for nominal consideration, and then pays a substantial dividend to Mrs. ...

4 May 2016 External T.I. 2016-0634551E5- Ss 191(4) and PAC-- summary under Price Adjustment Clause Summary Under Tax Topics- General Concepts- Price Adjustment Clause effectiveness of share price adjustment clause on previously redeemed preferred shares can trigger Part VI.1 tax CRAindicated that the operation of a price-adjustment clause on previously-redeemd preferred shares to reduce their redemption amount to less than their specified amount would result in the requirement in s. 191(4)- that the specified amount not exceed the fair market value of the consideration for which such shares were issued- not being met. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 93.2(2) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(2) membership interest in Dutch cooperative ruled to be shares Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in consideration for a credit to the membership accounts of the contributing foreign affiliates equal to the FMV of the contribution, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2 and that membership interests in DC will be deemed to be shares of a single class by s. 93.2(2). ...

7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F- Critical Illness Insurance-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) benefit on gratuitous transfer of critical illness policy by corporation to its shareholder CRA noted respecting the transfer for no consideration of a critical illness insurance policy by Opco (which was the policyholder, beneficiary and had paid all the premiums) to its shareholder (so that the shareholder became the holder and beneficiary) to Holdco, that although no capital gain would arise on the transfer to Opco, under s. 15(1) “the value of the benefit could correspond to the FMV of the policy.” ...

8 October 2010 Roundtable, 2010-0373471C6 F- Actions fictives-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement phantom share analysis is fact sensitive As consideration for bringing new employees to a Canadian corporation (“Opco”), Serviceco is issued phantom shares of Opco which generate cash payments equaling the dividends paid on corresponding common shares of Opco and which, on a change of control, are convertible into common shares of Opco. ...

1 October 2010 External T.I. 2010-0378681E5 F- Déduction pour gain en capital-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) s. 84.1)1) engaged on sale of Opco to Sonco for note Would the capital gains deduction be available to an individual who disposes of all of the shares of "Opco") to another corporation ("Sonco") held by the individual’s adult son, in consideration for a 10-year interest-bearing note payable over 10 years/ CRA stated: [A]ll the conditions for the application of subsection 84.1(1) would be satisfied … [thereby] result[ing] in a dividend rather than a capital gain …. ...

8 September 2009 External T.I. 2008-0299771E5 F- Gain on Disposition of Debt-- summary under Subsection 43(1) Summary Under Tax Topics- Income Tax Act- Section 43- Subsection 43(1) partial repayment of low-ACB debt generates a capital gain Over the years, A made advances (the "Debt") to Aco which it wholly owned, and then sold all the shares of A to an arm’s length purchaser, as well as the Debt for nominal consideration. ...