Search - consideration

If the marketable securities are transferred by the parent to the subsidiary and, as consideration for that transfer, the parent acquires shares of the subsidiary and, at the same time, control of the subsidiary (in a case, for example, where the parent would not have been the incorporator of the corporation), would the marketable securities be eligible for the bump under paragraph 88(1)(c)? ...

Policy considerations surrounding compliance, the language of the Act, and the clear purpose behind Part XIII do not allow for relief through an expansion of the certification system. ...

All of the New Common Shares will be cancelled in consideration for an amount equal to the Final Distribution. ...

As consideration therefor, E LP issued XXXXXXXXXX partnership units (representing approximately XXXXXXXXXX% of all the issued E LP partnership units) to Lossco and assumed all of the liabilities associated with the Loss Business. ...

Subsection 245(2) will apply to determine the tax consequences of the series of transactions described in Paragraphs 16 to 18 such that the repayment of the subordinated debt referred to in Paragraph 18 will be considered a settlement of the subordinated debt for no consideration for the purposes of applying section 80. ...

(ii) "Share" means a limited liability company interest in the LLC; (iii) "Stockholder" means each person signing the LLC Agreement and any person who subsequently obtains Shares in the LLC, in each case in its capacity as a Stockholder of the LLC; (iv) "Capital" of Shares is the aggregate of all amounts paid to the LLC and the monetary value at the time of contribution of property contributed to the LLC (in each case including amounts paid or contributed prior to D Co's conversion to an LLC) 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 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 Agreement. ...

For greater certainty, the CRA has not considered, confirmed or made any determination in respect of: (a) any income tax considerations associated with the Conversion Transaction, as described in 13 above; (b) whether the Amendments will result in the creation of a new trust under the laws of the Province of XXXXXXXXXX; (c) whether Trust is, at any particular time, a mutual fund trust within the meaning of subsection 132(6) of the Act; and (d) the appropriate characterization of the Trust Units under GAAP or IFRS. ...

However, it is to be noted that, pursuant to subparagraph 40(2)(g)(ii) of the Act, a taxpayer's loss arising from the disposition of a property is nil unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...

LP was formed by way of execution of the LP Agreement and contribution of $XXXXXXXXXX by each of GPCo and the Trust in consideration of LP Units. ...

3 October 2011 External T.I. 2011-0421341E5- Paragraphs 55(3.1)(c) or (d) Unedited CRA Tags 55(3.1)c) and d) Principal Issues: Whether paragraph 55(3.1) (c) or (d) would apply as a result of the disposition by the distributing corporation in favour of a non-related person of real estate for cash consideration prior to a butterfly reorganisation. ...