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17 June 2013 Internal T.I. 2013-0475621I7- PUC adjustment-- summary under Subsection 85(2.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(2.1) A non-resident corporation and another taxpayer transferred forward purchase agreements (FPAs) and promissory notes to a Canadian corporation in consideration for the issuance of common shares and jointly filed a T2057 election form. ...

5 October 2012 APFF Roundtable, 2012-0454241C6 F- Double imposition-- summary under Subsection 160(2) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(2) ETA s. 325 assessment in same audit is issued after ITA s. 160 to avoid double tax/no priority accorded to ARQ A, who is indebted to each of CRA and Revenue Quebec (ARQ) for $50,000, transfers $10,000 of property to A's spouse (B) for no consideration. ...

13 August 2013 External T.I. 2012-0471401E5 F- FMV- partnership interest-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other deferred tax liability re deferred (s. 34) partnership income recognition reduces partnership interest FMV A partner of a professional partnership which has elected under s. 34 to exclude work-in-progress from its income transfers his partnership interest to a corporation in consideration for preferred shares, utilizing the s. 85(1) election. ...

CRA stated (TaxInterpretations translation) in indicating that a higher sale price should be imputed to Canco: [A]fter consideration of various provisions of the Act, such as section 68 and 69 as well as subsections 14(1), 56(2) and 247(8), it appears to us that the primary adjustments respecting Canco should, where appropriate, be through an application of subsection 247(2). ...

Consideration should also be given, inter alia, to the possibility that the employment contract may be renewed and evidence of an intention to work there temporarily or otherwise. ...

16 February 2016 External T.I. 2015-0618601E5- Earned or Unearned Revenue-- summary under Subsection 56.4(2) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(2) no deferral of lump sum received on signing 15-year supplier loyalty agreement The taxpayer received a lump-sum payment (the “Payment”) from a major supplier (“ACo”) in consideration for entering into a supplier loyalty agreement (the “Agreement”). ...

16 February 2016 External T.I. 2015-0618601E5- Earned or Unearned Revenue-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) lump sum received on signing 15-year supplier loyalty agreement was immediately recognized inducement The taxpayer received a lump-sum payment (the “Payment”) from a major supplier (“ACo”) in consideration for entering into a supplier loyalty agreement (the “Agreement”). ...

[T]he comments of the Supreme Court of Canada on the considerations mentioned in previous paragraphs could still be relevant. ...

CRA first noted that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value. ...

…[W]e have referred this matter…for [Finance’s] consideration in the finalization of the proposed legislation. ...