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Before concluding that for purposes of applying the eligible capital expenditure definition to the Canadian shareholder, the expenditure incurred by it would be considered to be equal to the FMV of the property at the time of its distribution, CRA stated: [T]he cost of a property received by a corporation from its shareholder for no consideration, for example as a capital contribution, would…result in the corporation having a cost of the property equal to its FMV. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration S. 95(2)(c) which, insofar as relevant to the question of how it dovetails with s. 93.2, is essentially identical to s. 85.1(3). ...

14 May 2012 External T.I. 2011-0426631E5- Donation of Flow-through Shares-- summary under Section 38.1 Summary Under Tax Topics- Income Tax Act- Section 38.1 CRA was asked to consider transactions in which a limited partnership holding flow-through shares transferred those shares to a mutual fund corporation in consideration for shares of the mutual fund corporation (presumably, under s. 85(2)), those shares (the "MFC shares") were distributed to the limited partners on the winding-up of the partnerships (presumably under s. 85(3)), and the MFC shares were donated by the former partners. ...

14 May 2012 External T.I. 2011-0426631E5- Donation of Flow-through Shares-- summary under Subsection 40(12) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(12) CRA was asked to consider transactions in which a limited partnership holding flow-through shares transferred those shares to a mutual fund corporation in consideration for shares of the mutual fund corporation (presumably, under s. 85(2)), those shares (the "MFC shares") were distributed to the limited partners on the winding-up of the partnerships (presumably under s. 85(3)), and the MFC shares were donated by the former partners. ...

The 23% withholding tax under ITA s. 212(5.1) on the gross consideration paid could be avoided if the corporation files a Part I return for the year by its filing due date therefor and elects therein to have s. 216.1 apply. ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 248(5) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt dividends to Canco) to another wholly-owned subsidiary (Luxco1). ...

17 May 2011 External T.I. 2010-0391651E5- Royalty payment in IP-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) payment to employee of royalties, generated from IP developed by the employee in the course of employment and assigned to the employer, was employment income A faculty member employed by the university generates IP in performing research in the course of that employment, which is assigned to the university in consideration for a share of any royalties that are generated as a result of the university’s commercialization of that IP. ...

The election in subsection 45(3) cannot be made in the situation under consideration. ...

D transferred D’s Opco shares to Holdco in consideration for a non-voting preferred share and a note. ...

8 October 2010 Roundtable, 2010-0373611C6 F- Certificat avant distribution-- summary under Subsection 159(3) Summary Under Tax Topics- Income Tax Act- Section 159- Subsection 159(3) directors of corporate trustee generally are generally not liable under s. 159(3) A trust, whose sole trustee is a corporation, acquired, as its only asset, a property valued at $50 million (the "Property") in consideration for the issuance of a note payable in the same amount, and then disposed of the Property and used the proceeds to repay the note. ...