Search - consideration

. … [I]n this context … the consideration to be received by customers is … the XXXXXXXXXX service offered by the corporation. ...

In the 10th year, the corporation assigns the insurance policy without consideration to the shareholder, who pays the premium due for the 10th year and then receives a full refund of all premiums paid during the term of the policy. ...

Accordingly, the individual shareholder of Managementco transfers his shares of Managementco to Opco in consideration for shares of Opco and Managementco is wound-up into Opco. ...

The two quota holders of Eco agree that the principal assets of Eco will be assigned to a newly-incorporated corporation in the same foreign jurisdiction ("Jco") for no consideration; but that contemporaneously with the creation of Jco and the assignment of property of Eco to Jco, the capital account and retained earnings of Eco will be reduced and added to the capital and retained earnings of Jco (which is owned by Dco and Fco in the same proportions as they owned, and continue to own, Eco). ...

The two quota holders of Eco agree that the principal assets of Eco will be assigned to a newly-incorporated corporation in the same foreign jurisdiction ("Jco") for no consideration; but that contemporaneously with the creation of Jco and the assignment of property of Eco to Jco, the capital account and retained earnings of Eco will be reduced and added to the capital and retained earnings of Jco (which is owned by Dco and Fco in the same proportions as they owned, and continue to own, Eco). ...

The two quota holders of Eco agree that the principal assets of Eco will be assigned to a newly-incorporated corporation in the same foreign jurisdiction ("Jco") for no consideration; but that contemporaneously with the creation of Jco and the assignment of property of Eco to Jco, the capital account and retained earnings of Eco will be reduced and added to the capital and retained earnings of Jco (which is owned by Dco and Fco in the same proportions as they owned, and continue to own, Eco). ...

11 May 2004 External T.I. 2004-0069521E5 F- Don de biens culturels-- summary under Subsection 248(32) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(32) s. 248(32) inapplicable where contract of sale rather than deed of gift After indicating that s. 248(32) “does not create a presumption of gift where the value of the consideration received by a donor is less than 80% of the value of the property donated but there is otherwise no gift because of the absence of an intention to give,” CRA indicated that it could apply where a taxpayer transferred, by deed of gift, property to a designated cultural institution, pursuant to s. 32(2) of the Cultural Property Export and Import Act and received a lump sum from the institution that was less than 80% of the FMV of the property (with the Canadian Cultural Property Export Review Board determining that the criteria of significance and importance were satisfied), but not to a comparable transaction where the transfer occurred by way of contract of sale. ...

31 May 2004 External T.I. 2004-0074381E5 F- Créance: calcul des intérêts-- summary under Subsection 20(21) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(21) overview of s. 20(21) In the course of a general discussion, CRA stated: [W]here accrued interest has been included in the transferor's income and the debt obligation is disposed of for consideration equal to its fair market value, that taxpayer may deduct pursuant to subsection 20(21) the amounts of interest on that debt obligation that were included in computing the taxpayer's income for the year of disposition and all preceding years in excess of the total interest actually received or receivable that the taxpayer has not repaid to the issuer of the debt obligation on that debt obligation. ...

27 May 2004 External T.I. 2003-0031231E5 F- Actions visées par règlement-gel successoral-- summary under Subparagraph 6205(2)(a)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2)- Paragraph 6205(2)(a)- Subparagraph 6205(2)(a)(i) test satisfied where the purpose was solely estate-freezing Three brothers (A, B and C), who were the equal common shareholders of ABC, each effected an estate freeze in favour of a discretionary trust for the benefit of himself, his wife and their descendants, so that their common shares of ABC were converted into preferred "freeze shares" and new common shares (assumed to be prescribed shares) were issued for nominal consideration to the respective family trusts (Trusts A, B and C). ...

A had been actively engaged on a regular and continuous basis for 18 months) on a s. 85(1) rollover basis to a corporation in consideration for shares, and then sold the shares two, or six, months later. ...