Search - consideration

Holdco purchased the preferred shares for cancellation in consideration for the issuance of preferred shares denominated in Canadian dollars. ...

Salesco and OpCo2 purchase for cancellation all the issued and outstanding Class A shares (held by USSalesco1) for cash or promissory note consideration equal to the shares' fair market value. ...

The estate will transfer its remaining Class A shares to Newco in consideration for Newco issuing Note 2 (with an amount equal to the ACB of the transferred shares) and a common share, with a joint election being made under s. 85(1). ...

11 March 2014 Internal T.I. 2013-0506801I7- Salary and Wages, Part IV of the Regulations-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) no s. 8 deductions; payroll of PEs outside Canada included Respecting the application of the definition of "salary or wages" in s. 248(1), CRA stated that "subsection 402(3) of the Regulations contemplates only the salaries and wages paid by the corporation to the employees, which precludes consideration of the deductions available to an employee under section 8. ...

10 September 2012 External T.I. 2012-0446921E5 F- Avantage pour automobile-- summary under Paragraph 85(1)(e.4) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e.4) car acquired at cost equal to FMV for standby charge purpose notwithstanding s. 85(1) election In 2012, Corporation A disposed of an automobile that had been acquired by it in 2009 at a cost of $40,000 and used by a joint employee of it and a related corporation (Corporation B) to Corporation B, for consideration equal to its fair market value of $25,000, with the automobile continuing to be used by the employee in the course of such joint employment. ...

10 October 2014 APFF Roundtable, 2014-0538261C6 F- Disposition of capital interest/personal trust-- summary under Cost Amount Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Cost Amount note issuance is not trust property distribution to a beneficiary In order to settle the capital interest in a discretionary family trust of a beneficiary who is related to the trustees, that beneficiary agrees to renounce his interest in consideration for $200,000 paid by the trust as to $50,000 in cash and as to $150,000 by the issuance of a promissory note due by the trust in 5 years' time and bearing interest at 5%. ...

10 October 2014 APFF Roundtable, 2014-0538261C6 F- Disposition of capital interest/personal trust-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) non-deductible interest on note issued to beneficiary In order to settle the capital interest in a discretionary family trust of a beneficiary who is related to the trustees, that beneficiary agrees to renounce his interest in consideration for $200,000 paid as to $50,000 in cash and as to $150,000 by the issuance of a promissory note due in 5 years' time and bearing interest at 5%. ...

[W]e have not had the opportunity to give full consideration to whether the above position should apply for purposes of [s. 104(4)(a).] ...

12 February 2014 Internal T.I. 2012-0443391I7- cross-border loans and deductibility of interest-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) interest deductible when satisfied with common shares issued in pre-FAD-rule foreign afiliate dumping transactions Canco purchased common shares of Foreign Sub (a subsidiary of Parentco) from its foreign parent (Parentco) in consideration for treasury shares. ...

After noting that Chan indicated that a distribution under s. 107(2) is an allotment made in accordance with the beneficiary's interest and not made for consideration, CRA stated: Under the law of equity, fiduciary duties are imposed on a trustee and are enforceable by the beneficiaries of a trust. ...