Search - consideration

. … As to the nature of the income that would have arisen to Corporation at the time of the exercise of the options, we are of the view that this is consideration for the services that were to be rendered by Corporation to Publico. … Consequently, the income generated on the exercise of options granted by Publico would normally be added to the Corporation's business income under subsection 9(1). ...

A, the Directorate first noted that “For this provision to apply, the CRA must establish that the disposition of Class "F" shares of the capital stock of Opco … was part of the series of transactions or events in which Opco acquired the Class "AA" shares of its capital stock for consideration less than their fair market value,” and then stated: Although the “because of” or “in relation to” test [in Copthorne] of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

21 October 2013 Internal T.I. 2013-0505831I7- Rollover and subsequent disposition of property-- summary under Paragraph 69(11)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(11)- Paragraph 69(11)(b) s. 69(11)(b) inapplicable to s. 85.1(3) drop-down of CF1 to CF2 followed by sale of CF1 "exempted" by s. 2(3) The taxpayer, a Canadian corporation, transferred all its voting and participating shares of Subco, a non-resident subsidiary wholly-owned corporation, to Forco (another controlled foreign affiliate) in consideration for shares of Forco. ...

21 October 2013 Internal T.I. 2013-0505831I7- Rollover and subsequent disposition of property-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) s. 69(11)(b) not applied The taxpayer, a Canadian corporation, transferred all its voting and participating shares of Subco, a non-resident subsidiary wholly-owned corporation, to Forco (another controlled foreign affiliate) in consideration for shares of Forco. ...

Turning to the "resident beneficiary" requirement, which required that there be a "connected contributor," CRA stated: When determining if an estate created on someone's death has a connected contributor, the relevant consideration is whether the deceased was a resident of Canada immediately before death or within 18 months of death. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Subparagraph 39(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(ii) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...

It follows in our view that amounts paid to a qualifying person by a purchaser of EFA contracts because of the potential for future profits that could be derived from those contracts for future services to be rendered would not be paid in consideration for the disposition, by the qualifying person, of its interest in an EFA or an interest in a trust governed by an EFA. ...