Search - consideration

In this regard, the cost of a property acquired by a corporation issuing shares as consideration for the acquisition of the property is equal to the amount credited to the stated capital of such shares. ...

13 July 2018 Internal T.I. 2017-0713301I7- Assumption of accrued interest-- summary under Paragraph 212(13.1)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(13.1)- Paragraph 212(13.1)(a) withholding when debt of Canadian partnership assumed by sub As part of the consideration for the drop-down of the assets of a Canadian partnership (whose partners were Canco and its wholly-owned Canadian subsidiary) to a wholly-owned U.S. subsidiary (“Debtor Affiliate”), Debtor Affiliate assumed the loan including accrued interest thereon that had been owing by Partnership to another Partnership subsidiary (“Creditor Affiliate”), and Creditor Affiliate released the Partnership from its obligations on the Loan. ...

29 April 1994 External T.I. 9336625 F- Attribution Rules-- summary under Subsection 74.5(2) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(2) s. 74.5(2) exception ceases to apply when transferee spouse refinances loan from transferor spouse An individual (the Transferee) acquired an income producing property from the Transferee’s spouse (the Transferor) in consideration for a demand promissory note bearing interest at the prescribed rate at that time. ...

CRA stated: Subject to subsection 51(4) of the Act, section 51 will apply to any situation where a share of the capital stock of a corporation is acquired by a taxpayer in exchange for a capital property that is another share of the particular corporation and no other consideration is received for the old shares. ...

If the decrease in the adjusted cost base of the partnership interests is a result of losses of the partnership, the amount of borrowed money used to acquire the consideration for purposes of s. 20.1(1)(b)(i) would be based on the fair market value the property received in satisfaction of the partnership interests and the original cost of the partnership interests. ...

" However, on the acquisition of the common shares by virtue of the conversion of the preferred shares to common shares, the foundation would be providing the preferred shares as consideration. ...

[W]here the use of the tennis courts and weight/exercise room and all other services are available to members in consideration for membership fees and per use charges, the corporation would generally be considered to be carrying on an active business. ...

A would have disposed of property for consideration equal to the decrease in the FMV of the common shares he held, pursuant to paragraph 69(1)(b). ...

Sec. 9 ITA-- summary under Paragraph 12(1)(a) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(a) prepaid crypt fees of funeral home were includible under s. 12(1)(a) A funeral home (“Opco”) granted 99-year concessions to “Buyers” of a niche or crypt located in a columbarium or mausoleum in consideration for an up-front lump sum. ...

Sec. 9 ITA-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) prepaid crypt fees of funeral home were ineligible for s. 20(1)(m) reserve A funeral home (“Opco”) granted 99-year concessions to “Buyers” of a niche or crypt located in a columbarium or mausoleum in consideration for an up-front lump sum. ...