Search - consideration

We have also taken into consideration that the… property and values were accurately described. ...

However, it should be taken into consideration that she has already been taxed on the income allocated to her by Trust. ...

Furthermore, the taxable income and taxable capital employed in Canada of a subsidiary for the taxation year of its winding-up must be taken into consideration for the purposes of paragraphs 157(1.3)(b) and 157(1.4)(b) to determine whether the parent qualifies as a SCCPC [small CCPC] since the parent and the subsidiary are associated in the course of the particular taxation year by virtue of paragraph 256(1)(a). ...

11 June 2013 STEP Roundtable Q. 9, 2013-0480351C6- STEP CRA Roundtable Q9- June 2013-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) meaning of sale in Sommerer Respecting whether CRA accepted Sommerer, it stated that the decision stood: for the general proposition that where property is transferred to a trust by a beneficiary of the trust in return for consideration that constitutes a fair market value, subsection 75(2) will not apply to attribute income in respect of that property to that beneficiary. ...

Mr X sells all his shares of Corporation A to Corporation B in consideration for a promissory note, resulting in his receipt of a deemed dividend under s. 84.1(1)(b) that is less than the GRIP of B. ...

2013 Ruling 2013-0490341R3- No-type of property spin-off butterfly-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) post butterfly FX loan by TC to DC Preliminary/butterfly reorg The shareholders of Old Pubco (a Canadian public corporation dealing at arm's length with each shareholder) will transfer all their Old Pubco common shares to a newly-incorporated Canadian subsidiary of Old Pubco (New Pubco) in consideration for New Pubco common shares. ...

26 June 2013 External T.I. 2013-0490711E5 F- Disposition en contrepartie de 1$-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) nature of Quebec gift Could the acquisition of a property for consideration of one dollar qualify as an acquisition by gift for purposes of s. 69(1)(c)? ...

X transfers the Class C shares to a newly-incorporated corporation of which he is the sole shareholder ("Holdco") in consideration for common shares, electing under s. 85(1). ...

If the emphyteusis is made for consideration, the sum so provided, whether payable in a lump sum or by instalments, is considered as proceeds of disposition of a right of emphyteusis or of part or all of the property subject to the emphyteusis. ...

If the emphyteusis is made for consideration, the sum so provided, whether payable in a lump sum or by instalments, is considered as proceeds of disposition of the proceeds of disposition of a right of emphyteusis or of part or all of the property subject to the emphyteusis. ...