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-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as absolute payment for the transfer of s. 28 inventory In finding that a cash-basis farmer realized income on the transfer of inventory for a promissory note, CRA stated: Since the promissory note was accepted as consideration for the transfer of the inventory, and given that none of the documents provide any remedy for non-payment, it appears that payment could only be enforced under the terms of the promissory note. ...

14 July 1998 Internal T.I. 9808476- BROADCASTER ACQUIRING EQUITY INTEREST-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition A Canadian producer would be considered to have disposed of a portion of its beneficial interest in a television production when it entered into a licence agreement with a broadcaster under which in consideration for a licence fee it agreed to pay the broadcaster 10% of all revenues derived from exploitation of the episodes, merchandise and ancillary products throughout the world in perpetuity with the broadcaster, in addition to receiving broadcasting rights, receiving other rights including ICRS rights, merchandising rights and development rights but without any transfer of copyright ownership. ...

15 August 2018 Internal T.I. 2018-0749931I7- Subsections 87(1), (1.1) and (4)-- summary under Subsection 87(4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(4) outside basis is not lost on a horizontal short-form amalgamation CRA confirmed the continuing correctness of the statement in S4-F7-C1, Amalgamations of Canadian Corporations, para. 1.74 that: Where shares of a predecessor corporation are cancelled for no consideration pursuant to a short-form horizontal amalgamation, the adjusted cost base of such cancelled shares to the shareholder will be added to the cost of the common shares of the new corporation which are deemed to have been received by the shareholder on the amalgamation under subsection 87(1.1). and noted that this position was based on #F9830205, dated May 18, 1999. ...

31 May 1994 External T.I. 9411795- INTERSPOUSE TRANSFERS AND RRSP'S-- summary under Subsection 74.1(1) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(1) Where an individual transfers cash to a spouse for no consideration, the spouse contributes the cash to an RRSP of which she is the annuitant, the spouse claims a contribution deduction under s. 146(5) and later withdraws the money, the total amount received by her out of the RRSP will be income from substituted property and included in the individual's income under s. 74.1(1) and will not be income of the spouse. ...

BUSINESS INCOME-- summary under Subsection 129(4.1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4.1) Where a corporation whose principal business is farming owns certain rights to take petroleum from a well located on the farm land and leases such rights to an arm's length third party in consideration for a royalty, the royalty income will not be considered to be incidental to or to pertain to the corporation's farming business, nor will the rights be considered to be held or used principally for the purpose of gaining or producing income from the farming business. ...

In valuing an equitable interest in a trust that has been donated, "the general approach is to value the various interests taking into consideration the fair market value of the property itself, the current interest rates, the life expectancy of any live tenants, or current terms of certain tables, and any other factors relevant to this specific case. ...

At law a gift is a voluntary transfer of property without consideration; a premium is basically an amount paid in order to obtain a "retirement income" (defined in subsection 146(1) of the Act). ...

Similar considerations apply where the RRSP is required to leave cash as margin on deposit with a broker to cover the possible exercise of a put option that the RRSP has written. ...

27 January 1994 External T.I. 9332575 F- Attribution of Income-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) S.75(2) will apply where the terms of the trust provide that the transferor of property to the trust (including a transfer for fair market value consideration) may have the property revert to her under the terms of the trust where the last of the other beneficiaries under the trust dies. ...

31 March 1995 External T.I. 9430115- interest in a family farm partnership & capital gains RESERVE-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) A reserve may not be claimed where an individual transfers property to a partnership pursuant to s. 97(1) and receives as consideration a promissory note payable over five years. ...