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Essentially the same considerations apply to a s. 97(2) election. ...

13 July 2004 External T.I. 2004-0058141E5 F- Transfert du droit aux revenus provenant d'un bien-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) rollover not available to assignment of the rents from a rental property to a corporation for shares since the transferee was a deemed trust under s. 248(3) A couple transferred, to their jointly-owned corporation, the right to receive the income from a Quebec rental property for a specified period, in consideration for preferred shares of the corporation. ...

2004 Ruling 2004-0084311R3- Incorporating a Partnership-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) On the transfer of the assets of a partnership to a corporation ("Newco") in consideration for shares and a promissory note, for reasons of legal simplification the shares and note are issued in the respective names of the partners (based on their pro-rata share) instead of the name of the partnership, with such pro-rata interest then being distributed to the respective partners on the subsequent wind-up of the partnership under s. 85(3). ...

2004 Ruling 2004-0084311R3- Incorporating a Partnership-- summary under Subsection 85(2) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(2) On the transfer of the assets of a partnership to a corporation ("Newco") in consideration for shares and a promissory note, for reasons of legal simplification the shares and note are issued in the respective names of the partners (based on their pro-rata share) instead of the name of the partnership, with such pro-rata interest then being distributed to the respective partners on the subsequent wind-up of the partnership under s. 85(3). ...

17 December 2004 External T.I. 2004-0084881E5- Deductibility of interest on assumed debt-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) assumption in consideration for asset purchase Respecting a question whether the assumption by a trust of another person's indebtedness (a loan payable by a corporation to "Finco") as part of the purchase price of an asset (a note payable by another trust), CRA noted that if a taxpayer has assumed another person's indebtedness as part of the purchase price of an asset acquired by the taxpayer, interest paid on the assumed debt generally is deductible under s. 20(1)(c)(ii). ...

X) for a cash consideration of $500,000 which Mr. A then lends to Farmco, with Farmco using the loan proceeds to redeem the Farmco shares held by Xco, would be considered to be non-arm's length transactions that were subject to s. 84.1(1)(b). ...

.-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) question of fact whether post-drop-down loan is boot A corporation ("Company A") disposed of a real estate property to a limited partnership in consideration for partnership interest and the assumption of indebtedness, and thereafter was lent money pursuant to an interest-bearing note by the partnership. ...

6 November 2001 External T.I. 2001-0105945 F- INTERETS LUDCO SINGLETON-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) scope of study on impact of Ludco and Singleton CCRA was studying the impact of Ludco and Singleton on various issues including the deductibility of interest on money borrowed to pay dividends or redeem shares, to acquire the shares of a corporation that is amalgamated with the acquiring corporation, to make a loan at less than a reasonable rate of interest or to honour a guarantee for inadequate consideration, to acquire common or preferred shares or to make interest-free loans to employees. ...

2001 Ruling 2001-0108873- LEVERAGED BUY-OUT-- summary under Subparagraph 20(1)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) target transferred post-acquisition to internal buyco and amalgamated After Acquisitionco acquires Target, Acquisitionco transfers all the shares of Target to a newly incorporated sub ("Newco") in consideration for common shares and a promissory note of Newco. ...

2002 Ruling 2001-0107613- EMPLOYEE OPTION TRANSFERS-- summary under Paragraph 7(1)(c) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(c) Where an arm's length employee transfers options to a personal holding company for no consideration, he will not, except as provided by s. 7, be deemed to have received or enjoyed any benefit under or because of the options or their transfer to the corporation. ...