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Transactions Amalco MFC will transfer all of its assets to the Fund in consideration for the assumption of its liabilities and the Fund’s agreement to issue Fund Units to the holders of the Amalco MFC Class A and B Shares in satisfaction of the redemption price for their shares (see 2 below), with a joint s. 132.2 election being made in due course. ...

Respecting the PPT’s application to CIVs issues, CRA will give consideration to matters such as other articles in the particular covered treaty, e.g., para. 7(a) of the Canada-France Treaty, any relevant competent authority agreement, e.g., the Canada-Netherlands agreement regarding closed funds for mutual account and previous rulings, e.g., on Switzerland contractual investment funds and Ireland common contractual funds. ...

A wholly-owned subsidiary of Canco 1 (Canco 2) will agree to repay the Loan on behalf of Canco 1 at maturity and in consideration for that undertaking, Canco 1 will issue a Canadian dollar denominated note (the “Canco 1 Note”), with an equivalent Canadian-dollar principal, to Canco 2. ...

CRA stated: Subsection 148(8) … provides that, if an interest of a policyholder in a life insurance policy (other than an annuity contract) is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of the disposition equal to the adjusted cost basis of the interest immediately before the transfer, and to have been acquired … at a cost equal to those proceeds. ...

It was proposed that the acquisition by CanSub2 of the ForSub1 shares be followed by their s. 85.1(3) drop-down to a foreign subsidiary of CanSub2 in consideration for common shares of equivalent value. ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1)(e.3) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e.3) purchaser could acquire Lossco’s business through a sub LP and then acquire Lossco, accessing s. 88(1)(e.3) A foreign-owned Canadian-resident corporation (“Taxpayer”) used a subsidiary LP to acquire the sole business of a “Lossco” that was in CCAA proceedings and then, a number of years later (and perhaps well after the completion of the CCAA restructuring) it purchases the shares of Lossco for nominal consideration and winds up Lossco. ...

In this regard, the cost of a property acquired by a corporation issuing shares as consideration for the acquisition of the property is equal to the amount credited to the stated capital of such shares. ...

7 August 1996 External T.I. 9605735- MEANING OF "DIRECTLY OR INDIRECTLY" IN 95(2)(A)-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) After being referred to an arrangement under which a foreign affiliate ("Forco"), which has made a loan to a related foreign subsidiary ("Xco"), assigns the loan to a foreign bank in consideration for a cash deposit that it maintains at the bank, and the bank lends an equivalent amount to Xco, RC stated: "In our view, in order to meet the words 'the income is derived from amounts that were paid or payable, directly or indirectly' in subparagraph 95(2)(a)(ii) of the Act, the amounts in question would have to be able to be directly traced. ...

A would have disposed of property for consideration equal to the decrease in the FMV of the common shares he held, pursuant to paragraph 69(1)(b),” CCRA further indicated that a price adjustment clause pursuant to the terms of the preferred shares pursuant to which their redemption value would be adjusted upwards pursuant to a board resolution to reflect the higher FMV was “not a type of price adjustment clause contemplated in … IT-169,” so that such clause would not stop such application of s. 69(1)(b). ...

In order that the individuals could hold high ACB shares in Opco directly various steps would be implemented including a sale by the individuals of their high-ACB shares of their Holdcos to Opco in consideration for high-ACB preferred shares of Opco. ...