Search - consideration

Subsequently, the shares of Luxco2 were contributed as capital contribution by Canco to Luxco1 without share consideration, and Canco then sold the shares of Luxco1 to a third party, thereby realizing a capital loss. ...

Before the expiration of the two-year s. 90(8)(a) limit, Canco sells its shares of FA to Foreign Parent for cash consideration. ...

X, who has for a number of years been the policy holder of a term life insurance policy (for 100 years) without a cash surrender value and an adjusted cost basis of $10,000, transfers the policy to his wholly-owned corporation (ABC Inc.) for no consideration, so that it becomes the policyholder and beneficiary and assumes the premium-payment obligations. ...

B, for no consideration, ½ of her preferred shares, thereby realizing under s. 73(1) proceeds of disposition deemed to be equal to the ACB of those shares of $500,000. ...

Since Child will not pay consideration to Father, the deemed trust would qualify as a personal trust within the meaning of subsection 248(1). ...

The Court of Quebec ruled in favor of the contributor in a decision animated more by considerations of fairness than by an analysis of the legislative provisions. ...

D transferred D’s Opco shares to Holdco in consideration for a non-voting preferred share and a note. ...

Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired..... ...

A, the Directorate stated: Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired …. ...

CRA responded: [W]e believe that the partner, in consideration for the $100,000 payment, acquired a greater interest in the partnership by acquiring part of a property. ...