Search - consideration

14 May 2019 CLHIA Roundtable Q. 2, 2019-0799051C6- 2019 CLHIA Roundtable- 148(7) questions-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) s. 6(1)(a) applied to transfer of life insurance policy to employee at an undervalue, notwithstanding the application of s. 148(7) As a result of an arm's length employee B no longer being considered to be a key employee, her employer (Corporation A) transfers its “key person” permanent life insurance policy on her life to her for nominal consideration. ...

14 May 2019 CLHIA Roundtable Q. 2, 2019-0799051C6- 2019 CLHIA Roundtable- 148(7) questions-- summary under Paragraph 148(7)(b) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(7)- Paragraph 148(7)(b) cost of policy gratuitously transferred to arm's length employee determined under s. 148(7)(b) rather than s. 52(1) As a result of employee B no longer being considered to be a key employee, her employer (Corporation A) transfers its “key person” permanent life insurance policy on her life to her for nominal consideration. ...

Bitcoin received by a miner to validate transactions is consideration for services rendered by the miner. ...

It was a question of fact whether the husband and wife could be considered to satisfy the excluded business test for a particular year or continue to meet such test thereafter, as consideration must be given to the ongoing nature and labour requirements of the corporation’s business. ...

It stated: Paragraph 400(2)(c) does not indicate that it is an exclusive (“notwithstanding”) or exhaustive (“means”) provision such that it would prevent consideration of any situation other than as described in this paragraph that would cause the taxpayer to otherwise have a PE, such as where a taxpayer as a partner has a PE in a province due to the partnership’s PE. ...

CRA proposed an inclusion in Canco’s income under s. 247(2) of the difference between an arm’s length price for goods sold by Canco to Sisterco LLC and the consideration paid, and also proposed a secondary adjustment under s. 247(12) on the basis that a resulting benefit conferred on Sisterco LLC was deemed to be a dividend that was paid by Canco that was subject to a Pt. ...

As consideration for corporation A issuing shares to the public, corporation A issues additional shares to corporation A. ...

Parentco transferred one of the two businesses to Splitco in consideration for Splitco common shares, and distributed those shares (the "Distribution Shares") on one of the two classes of its common shares (the “Original Shares”) on a tax-exempt basis under the Code. ...

More specifically: Aco establishes a new sister to Bco (Newco) to which Aco does an s. 85(1) drop-down of preferred shares of Bco having a fair market value equaling that of the trademarks; Bco spins-off the trademarks to Newco on a partial rollover basis in consideration for prefs of Newco, thereby using Bco’s net capital losses to effect a ½ step-up of the UCC of the trademarks under s. 13(7)(e)(ii) – and with Newco licensing the trademarks back to Bco for royalties; The prefs in 1 and 2 above are cross-redeemed (with reliance on the s. 55(3)(a) exception to s. 55(2)); Newco is wound-up under s. 88(1); Aco does an s. 85(1) drop-down of the trademarks back to Bco, but choosing an elected amount so as to uses up its net capital losses and to effect a further ½ step-up of the trademarks' UCC under s. 13(7)(e)(ii). ...

In consideration for the early termination of the lease, the new owner paid $15,000 to the tenant. ...