Search - consideration

2002 Ruling 2001-0107613- EMPLOYEE OPTION TRANSFERS-- summary under Paragraph 7(3)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(a) 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. ...

1 March 2002 External T.I. 2002-0118215 F- ACTIONS EMISES GRATUITES AUX EMPLOYES-- summary under Subsection 7(1.1) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.1) s. 7(1.1) continues to apply after issuing employer ceases to be a CCPC After indicating that the s. 7 rules were applicable to shares issued for no consideration to employees of a CCPC, CCRA went on to describe the application of the ss. 7(1.1) and 110(1)(d.1) rules, and stated: [S]ubsection 7(1.1) will continue to apply even if the corporation ceased to be a CCPC after the shares in question were issued. ...

2000 Ruling 2000-0010723- STOCK BONUS PLAN-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) A corporation ("TC") previously transferred a property to another corporation ("DC") and received non-voting preferred shares of DC as consideration. ...

24 October 2000 Internal T.I. 2000-0048177- 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 to redeem prefs Where a corporation redeems its preferred shares and, as consideration, assumes a bank loan that the shareholder had previously incurred to purchase business assets which subsequently had been transferred to the corporation, the interest on the assumed debt will be non-deductible notwithstanding that if the corporation had assumed the debt upon its acquisition of those business assets, the interest would have been deductible under s. 20(1)(c)(ii). ...

"We assumed that you share our views that the demand promissory note issued as consideration would not result in the Estate having factual control.... ...

17 November 1999 External T.I. 9901265- 97(1) AND A RESERVE-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) "[W]here an individual transfers property to a partnership under subsection 97(2) of the Act and receives, in addition to a partnership interest as consideration, a promissory note payable over, say, five years, the agreed amount would include the note and this amount would be deemed to be the proceeds for the individual and the cost to the partnership. ...

2019 Ruling 2019-0822951R3 F- Post-mortem Hybrid Pipeline-- summary under Subsection 40(3.61) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.61) s. 164(6) carryback of capital loss coupled with dividend to generate dividend refund Preliminarily to pipeline transactions, the CCPC that had been held by the deceased (ACo) will purchase for cancellation (in consideration for issuing a demand promissory note) a sufficient such number of its Class A common shares to result in a refund of its eligible refundable dividend tax on hand, or its non-eligible refundable dividend tax on hand, balances. ...

17 February 2021 External T.I. 2018-0768051E5 F- Contrat de crédit-bail-- summary under Substance Summary Under Tax Topics- General Concepts- Substance lease payments, but not the lease itself, could be recharacterized Regarding a lease of a truck tractor with a term of 48 months and a bargain purchase option at maturity, CRA indicated that the monthly rental payments should be allocated between deductible rental payments for the use of the vehicle and consideration for the option, which would be added to the adjusted cost base of the option. ...

After noting that “qualifying revenue" generally referenced “the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity,” CRA stated: [A] member's share of the profits of a partnership, as allocated to the member pursuant to subsection 96(1) and in accordance with the partnership agreement, is not "qualifying revenue" to the member …. ...

IV tax circularity issues are avoided by having a year end for the transferee corporation (Newco) occur between Newco’s purchase for cancellation of its preferred shares held by the distributing corporation (DC) in consideration for a demand note, and DC’s purchase for cancellation its shares held by TC for a demand note (so that TC is subject to Pt. ...