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Ruling

1999 Ruling 9902123 - CRYSTALLIZATION OF SAFE INCOME

As consideration for the transfer of the Converted Shares, Newco will issue to Holdings a number of Class A common shares with a fair market value equal to the fair market value of the Converted Shares at the time of the transfer. 12. ...
Technical Interpretation - Internal

25 June 1999 Internal T.I. 9905707 - RESOURCE ALLOWANCE

He stated: I make this finding [that the transactions in Echo Bay were hedges] after full consideration of the submissions advanced on behalf of the defendant that the transactions should not be so considered based on the fact that the transactions were carried out by the plaintiff's parent company, with no evidence before me of close consultation with the plaintiff's officers or employees. ...
Technical Interpretation - External

6 May 2019 External T.I. 2019-0791601E5 - METC & HATC for a dependant

In this regard, consideration would also be given to the amount of support provided by the individual. ...
Ruling

2018 Ruling 2018-0752531R3 - Public corporation election 89(1)(c)(i)

On XXXXXXXXXX, Pubco transferred all of its rights, title and interest in the XXXXXXXXXX Agreement, together with other related property, to Subco in consideration for the issuance of common shares of Subco. 16. ...
Ruling

2016 Ruling 2016-0671701R3 F - Loss consolidation arrangement

Elles donneront droit à un dividende semestriel cumulatif au taux décrit au Paragraphe 25 de la présente et elles seront rachetables au gré du détenteur ou de l’émetteur à un montant correspondant à la considération totale reçue lors de leur émission plus les dividendes impayés. 22. ...
Technical Interpretation - Internal

1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement

No consideration is paid for a PSP award or for shares acquired by an employee. ...
Conference

6 June 2019 CPTS Roundtable, 2019-0816111C6

Notwithstanding the breadth of the authority, CRA officials are expected to exercise their powers in a reasonable and supportable manner and with due consideration to audit scope, relevance and reasonableness, and transparency in carrying out their mandate. ...
Ruling

2020 Ruling 2019-0799981R3 - Disposition – Reclassification and Stock Split

(b) the application or interpretation of any foreign law or foreign tax considerations, relating to the Facts, Proposed Transaction or any transaction or event taking place either prior to the Proposed Transaction or subsequent to the Proposed Transaction, whether described in this letter or not. ...
Technical Interpretation - Internal

9 December 2019 Internal T.I. 2019-0818101I7 - Eligible Dependent Tax Credit

The Queen, 2013 FCA 69, where the Federal Court of Appeal (FCA) stated that, although the Federal Child Support Guidelines gave consideration to the incomes of both the payer and the recipient to determine the quantum of child support in that case, only the payer was considered to have, for purposes of the EDC, a legal obligation to pay a support amount. ...
Conference

26 November 2020 STEP Roundtable Q. 1, 2020-0839931C6 - Executor's Year of a GRE

If the personal representatives have discretion regarding the payment of income and can pay or accumulate it, the personal representatives have considerable flexibility, subject to the even-hand principle and other fiduciary considerations.” ...

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