Search - consideration

The new rules in proposed subsection 248(30) of the Act do not create a presumption of a gift where the value of the consideration received by a donor is less than 80% of the value of the property donated but there is otherwise no gift because of the absence of an intention to make a gift. ...

6 October 2006 Roundtable, 2006-0197211C6 F- Transfert de police d'ass-vie entre sociétés-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) could apply to the individual shareholder of Aco and Bco where Aco transfers an insurance policy at an undervalue to Bco CRA has indicated that where a corporation transfers an interest in a life insurance policy of which it is the owner to an individual who is its sole shareholder, there will be a s. 15(1) benefit equal to the excess of the fair market value of the interest in the life insurance policy over the consideration paid. ...

2015 Ruling 2015-0589471R3- Earnout-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) utilization of safe income as earned through a contemplated succession of dividends of all the annual earnings In connection with the implementation of an earnout transaction for the purchase of Holdco common shares by a key employee, the equal unrelated (corporate) shareholders of Holdco (a Canadian-controlled private corporation holding Opco) first transfer a portion of their Holdco common shares to Opco in consideration for tracking preferred shares of Opco, with Opco immediately selling those shares on a five-year earnout basis to the key employee. ...

After noting its position that where a lease had a bargain purchase option, a portion of each lease payment was to be treated as allocable to consideration paid for the option and not as deductible rent, CRA stated: [T]he payment of $5,000 made by Corporation B would, in all likelihood, be attributable to the option to purchase the property, which would constitute the acquisition cost of this option for Corporation B and the proceeds of disposition of this option to Corporation A. ...

If Yco did not so comply, consideration would be given to assessing Y beyond the normal reassessment period for a taxable dividend under s. 152(4)(a)(i). ...

Holdco had acquired the preferred shares of Employeeco (having no significant safe income) over the past five years as consideration for the transfer in each year of Opco common shares to Employeeco on a s. 85(1) rollover basis. ...

Holdco had acquired the preferred shares of Employeeco (having no significant safe income) over the past five years as consideration for the transfer in each year of Opco common shares to Employeeco on a s. 85(1) rollover basis. ...

After quoting from Petro-Canada, the Directorate stated: In considering this jurisprudence, we are of the view that in order to establish the reasonableness of the expense, one must establish what a reasonable business person would have undertaken to pay as a contribution to a retirement compensation arrangement with only the business considerations of the Corporation in mind. ...

A, who owned all the shares of Lossco, which had disposed of all the assets of its (unspecified) business for cash, disposed of those shares for FMV cash consideration to Profitco, which was owned equally by her and her three siblings. ...

The consideration for the goodwill, which has a value of $140,000 that consists of the assumption of a $100,000 loan and the issuance of preferred shares with a redemption amount of $40,000. ...