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22 September 2011 Ruling Case No. 129475-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply A for-profit corporation (the "Corporation") provides a service for fees to the families of non-resident minor children in consideration for arranging for them to study at a Canadian school district, stay at a Canadian home and participate in eight recreational activities to be arranged by the Corporation. ...

30 April 1990 T.I. 91042-4 [debt not assumed for income-producing property]-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) debt not assumed for income-producing property A B.C. corporation ("A") borrows money in order to acquire all the common shares of Opco, the shareholders of A transfer their shares of A to Opco in consideration for shares of Opco, and A is wound-up into Opco. ...

15 October 2004 Ruling RITS 52698-- summary under Paragraph 142(1)(c) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(1)- Paragraph 142(1)(c) situs of supply where resort points seized In connection with rulings on the consequences of the seizure by creditors and resale by them of resort points, the Directorate noted that the portion of sold resort points that was considered to be supplied in Canada was determined by prorating the consideration payable by a recipient of resort points based on the extent to which the resort points represented a right to use real property situated in Canada. ...

The parties agree to a $400 offset against the asset purchase price of $1,000 in consideration for the Purchaser's assumption of the Vendor's commitments. ...

13 December 2000 Ruling 31635-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) fees incurred to enhance shareholder value ineligible Respecting the fee paid by a corporation to a financial advisor regarding strategic alternatives for the enhancement of shareholder value including a potential sale of its shares or assets, the CCRA stated: From the letter of engagement, the costs do not meet the above criteria to be entitled to ITCs as they were not acquired for the purpose of making taxable supplies for consideration in the course of that endeavour. ...

28 March 2003 External T.I. 2002-016665-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Two shareholders collectively holding 24% of the shares of Opco transfer their shares of Opco to a newly-incorporated holding company ("Xyco") and Xyco purchases shares held by two of the other shareholders for a non-share consideration. ...

Although no rulings were given on the paid-up capital of the LLCs, the description of the "Shares" of the Delaware LLC ("LLC2") to be contained in the LLC Agreement- and similarly for California- stated: "Capital" of Shares is the aggregate of all amounts paid to LLC 2 and the monetary value at the time of contribution of property contributed to LLC 2 (in each case including amounts paid or contributed prior to USco 2's conversion to LLC 2) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 2 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 2 Agreement. ...

., a voluntary transfer of property without consideration and without conditions) is considered to occur where an individual has paid more for an annuity purchased from a charity than the total amounts expected to be received as annuity payments. ...

Paragraph (b) of the exclusion to the investment business definition would only be satisfied if the taxpayer could establish that each particular Landco employed the equivalent of more than five employees full-time in the active conduct of its business throughout the period in question taking into consideration the services provided by the employees of USCo. ...

The provision of such guarantees by the taxpayer for no consideration would not, in and by themselves, disqualify the taxpayer from satisfying the requirements of s. 132(6)(b). ...