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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. ...

.-- summary under Subsection 74.5(6) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(6) s. 74.5(6) applied to an estate-freeze exchange by individual’s Holdco of Opco common shares for preferred shares so that family trust could subscribe for Opco common shares An individual transferred all the common shares of Cco (which, at no point, was a small business corporation) in a s. 85(1) rollover to a Newco (Bco) in consideration for common shares of Bco (being all its common shares). ...

However, as the governing legislation did not permit Canco to invest in Foreignco shares, the sums agreed by Canco were agreed, as an informal contractual matter, to be the consideration for “special warrants” to acquire shares of Foreignco, with such warrants being redeemable by the holder for the FMV of the corresponding Foreignco equity. ...

However, as the governing legislation did not permit Canco to invest in Foreignco shares, the sums agreed by Canco were agreed, as an informal contractual matter, to be the consideration for “special warrants” to acquire shares of Foreignco, with such warrants being redeemable by the holder for the FMV of the corresponding Foreignco equity. ...

CCRA indicated the following consequences of the transfer of the policy by the corporation to the individual for no consideration: Pursuant to s. 148(1), the corporation was required to include $75,000 in income, being the excess of the deemed proceeds of disposition under s. 148(7) over the policy ACB ($125,000- $50,000). ...

The former partners or companies related to them enter into contractual arrangement with a newly-incorporated operating company whereby it will be able to utilize goodwill and related assets of the corporation in consideration for paying a licensing fee and also retaining the former partners for agreed-upon per diem fees. ...

However: In the event that the goods are transferred without monetary consideration to an individual qua employee, it appears to us that the transfer of the goods may not constitute a gift and subparagraph 69(1)(b)(ii) would not apply to the corporation. ...

17 December 2003 Internal T.I. 2003-0047727 F- Right of Use-Deemed Trust-- summary under Subsection 105(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(2) potential s. 105(2) benefit where Opco pays all of the expenses on its property to a portion of which the sister of Opco’s indirect controlling shareholder has a right of (personal) use An individual (“Sister”), who had been experiencing financial difficulties, disposed of her home, part of which she had been renting out, to Opco, which was a subsidiary of a corporation (“Holdco”) controlled and partly owned by her sister ("X") (with X’s children as common shareholders) for fair market value consideration. ...

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...