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[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. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 93.2(3) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(3) s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Canco owns all the shares of FA1, which owns all the shares of FA2 and all the member interests of FA3, which is a “non-resident corporation without share capital” as per s. 93.2(1). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) dropdown of shares made to an LLC as a contribution of capital deemed by s. 93.2(3) to be for "share” consideration FA1 (wholly-owned by Canco) transfers all of the shares of FA2 to another non-resident subsidiary of FA1, viz., a non-share corporation (“FA3”), as a capital contribution, i.e., no new member interests are issued by FA3. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Dutch cooperative whose articles limited member liability was a corp Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Netherlands cooperative (Dutch Co-op, or "DC"), in consideration for a credit to the membership accounts of the contributing foreign affiliates, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2. ...

Before paraphrasing the requirements under s. 60(1)(j)(i) for such a deduction, CRA stated: a foreign plan will be considered to be a superannuation or pension plan where contributions are made to the plan by or on behalf of the employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee’s retirement. ...

X in consideration for a stipulated sum, and the transfer was duly registered in the land register of Quebec. ...

X in consideration for a stipulated sum, and the transfer was duly registered in the land register of Quebec. ...

If it chooses to wait until the consideration for the receivables is payable and include the receivables in the beneficiary's return, subsection 70(3) may apply if an election is made before the expiry of the time allowed in subsection 70(2). ...