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8 October 2010 Roundtable, 2010-0373611C6 F- Certificat avant distribution-- summary under Subsection 159(2) Summary Under Tax Topics- Income Tax Act- Section 159- Subsection 159(2) repayment of note to unsecured creditor was a distribution A trust, whose sole trustee is a corporation, acquired, as its only asset, a property valued at $50 million (the "Property") in consideration for the issuance of a note payable in the same amount, and then disposed of the Property and used the proceeds to repay the note. ...

23 June 2010 External T.I. 2010-0365581E5 F- Règles d'attribution de l'article 74.2-- summary under Paragraph 74.5(1)(c) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(1)- Paragraph 74.5(1)(c) s. 74.2(1) inapplicable to transfer at FMV of property to a discretionary family trust, with capital gain on property subsequently distributed to spouse of transferor An individual disposed of capital property to a discretionary trust (whose beneficiaries were the individual and spouse and their children) in consideration for property (other than a debt obligation) having the same fair market value. ...

If he drops the pharmacy department down into a newly-incorporated corporation ("Pharmaco") and sells the commercial department to an arm's length corporation ("Opco B"), with Pharmaco agreeing to pay Opco B annual amounts equal to a percentage of Opco B's sales in consideration for Opco B agreeing to continue to carry on the acquired business (the commercial department), would such payments be deductible? ...

In this case, consideration should be given to requiring any excess investment earnings to be withdrawn from the Plan. ...

Headquarters will generally, in turn, refer the matter to the GAAR Committee for consideration. ...

Furthermore, the reporting entity would report their share of income and/or gains/losses with respect to specified foreign property on Form T1135, based on their ownership interest in the underlying property and without consideration given to the attribution rules. ...

CRA responded: In the first situation…[if] a genuine employment relationship existed… over the years and the corporation paid him or her a salary in consideration for his or her services rendered during those years, the failure to pay a wage to the individual during the two years preceding his death would not result in the amount paid by the corporation to the employee not being a death benefit. ...

12 January 2017 Internal T.I. 2016-0636911I7- Standby Charge- PST and the cost of an automobile-- summary under Subsection 6(7) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(7) car standby charge is reduced for the sales tax reduction occurring where a trade-in allowance is provided on the car purchase Where a trade-in forms part of the consideration paid for a purchased automobile, the amount of GST/HST and provincial sales tax (“PST”) payable on the purchase may be reduced to reflect the trade-in. ...

What would be the consequences if the RRSP transferred the Co-op shares to the annuitant for consideration equalling the cost of the shares to the RRSP, so as to return the RRSP to it previous position? ...

The individual transfers the policy to a wholly-owned corporation in consideration for two demand notes in respective amounts equalling the CSV, and the FMV excess over the CSV (i.e., $310,000). ...