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Proposed transactions The Estate will transfer its Class D shares to a corporation newly incorporated by it (Newco) in consideration for voting and participating shares of Newco, electing under s. 85(1). ...

The Queen-- summary under Employee Benefit Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Employee Benefit Plan trust providing for distributions of employer shares on a fully discretionary basis is not governed by s. 7 When asked to comment on the McNeeley decision, CRA stated: When contemplating the establishment of a trust which will acquire securities of an employer to be held for the benefit of employees, consideration of the EBP rules is advised. ...

After noting that, under s. 40(1)(a)(ii), the availability of the reserve turned on Brother-Portfolioco and Brother not having de facto control of Sister-Holdco and on Sister-Holdco not having de facto control of Brother-Portfolioco, CRA commented on the expansion of de facto control under s. 256(5.11) stating: As provided for in subsection 256(5.11) and the applicable jurisprudence, any factor, whether contractual, commercial, economic, moral or familial, may be taken into consideration in order to determine whether a person or group of persons has influence, direct or indirect, the exercise of which would result in de facto control of a corporation ("Influence"). ...

Following the death of Mother, her estate and Trust were to engage in a pipeline transaction under which: The estate and Trust transfer their Aco shares under s. 85(1) to a Newco of Trust in consideration for Newco preferred shares. ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) example of application of s. 7(1.31) to acquisition and immediate sale of shares pursuant to RSUs An employee who acquired 10 common shares of the employer, a public corporation, on capital account, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

An employee who acquired 10 common shares of the public-company employer, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

On the day for settlement of a redemption/repurchase transaction, there will be, in quick succession, a transfer by the registered plan of its Trust units to Buyco, a redemption of such units in the hands of Buyco for USco shares, and the repurchase of such shares by USco for consideration consisting of it directing that funds in a Canadian bank deposit previously held for it will thereupon be held for the benefit of the plan, thereby satisfying its obligation to pay the share repurchase price to Buyco, and Buyco’s obligation to pay the purchase price for the Trust units. ...

Although the Income Tax Rulings program is there to provide advance comfort on the tax consequences of a transaction, as noted in IC70-6R12, CRA will not confirm the fair market value of a property, and the Rulings program is not in a position to verify the facts provided – and there are also timing considerations. ...

The wording of the question begged the question by describing the transaction as a repayment of the purchase price rather than as a retroactive adjustment to the share consideration, but there was nothing in the wording of the response to suggest that it was sensitive to how the question was framed. ...

In consideration for this discontinuance, it agreed to make contributions to a trust to fund certain designated employee benefits as described in s. 144.1(1) for the New Hires. ...