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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. ...

13 July 2004 External T.I. 2004-0058141E5 F- Transfert du droit aux revenus provenant d'un bien-- summary under Subsection 248(3) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(3) assignment of the rents from a rental property to a corporation would result in a disposition to a deemed trust under s. 248(3) Monsieur and Madam will transfer, to their jointly-owned corporation, the right to receive the income from a rental property for a specified period, in consideration for preferred shares of the corporation. ...

13 July 2004 External T.I. 2004-0058141E5 F- Transfert du droit aux revenus provenant d'un bien-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) s. 75(2) applicable to assignment of the rents from a rental property to a corporation giving rise to a deemed trust under s. 248(3) A couple transferred, to their jointly-owned corporation, the right to receive the income from a Quebec rental property for a specified period, in consideration for preferred shares of the corporation. ...

Loss loss on equity swap entered into in monetization transaction was on capital account In connection with its monetization of the shares of a corporation, the taxpayer transferred the shares of that corporation to a Newco ("Corporation2") in consideration for shares of Corporation2, entered into an equity swap with a financial intermediary with respect to the shares of Corporation2 under which it agreed to pay the appreciation in the value of the shares of Corporation2 above a ceiling level, and the counterparty agreed to pay the depreciation in value of the shares of Corporation2 below a floor level, and the taxpayer borrowed money from another financial institution. ...

CRA found that s. 256(7)(d) deemed there to be no acquisition of control of OPCO given that: [T]he shares of the capital stock of OPCO were disposed of to another corporation (HOLDCO AB) for consideration that included shares of the capital stock of HOLDCO AB and immediately after the time of the disposition HOLDCO AB and OPCO were controlled by a group of persons (Mr. ...

Furthermore, Element E of the ACB requires consideration of policy loans repaid prior to the time of the ACB calculation. ...

20 December 2004 External T.I. 2004-0092871E5 F- Arm's Length: de facto control-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) Silicon Graphics has not changed the CRA view that the holder of a large demand note can have de facto control In 1999-0008405 F, CRA applied IT-64R4 in generally commenting that s. 84.1 could apply where an individual who sold the individual’s shares of a corporation to another corporation in consideration for a demand loan the value of which equaled 80% of the total value of such purchaser's assets. ...

If the facts show that the gain constitutes a portion of the consideration the consultant received for his or her services, the CRA feels that the gain must be treated as business income.... ...

A, a composer, will transfer to a newly-incorporated wholly-owned corporation (“Opco1”) his property used in his business of composer, including copyright (other than performance rights previously transferred to SOCAN, being a collective society described in s. 2 of the Copyright Act) and including his rights to royalties from SOCAN, in consideration for Opco1 shares; and will jointly elect with Opco1 for this transfer to occur on a rollover basis pursuant to s. 85(1). ...

23 March 2001 Internal T.I. 2000-0056097 F- Roulement interne-- summary under Subsection 84(1) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(1) s. 84(1) deemed dividend where individual’s low-PUC common shares are exchanged with the corporation for high-PUC preferred shares and there is an s. 85(1) agreed amount at FMV On an internal crystallization transaction, the corporation purchases the individual’s common shares, having a nominal stated capital, in consideration for the issuance of preferred shares with an equivalent FMV; and the agreed amount in their s. 85(1) election is also that FMV. ...