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Canco will sell all of its shares of CFA to Canco’s foreign parent for cash consideration equal to their fair market value and elect under s. 93(1) to the extent of any capital gain. ...

In relation to a sale of the shares of Opco by the two spouses to the Holdco of their adult child for non-share consideration, would Realtyco be considered a relevant group entity for purposes of s. 84.1(2.31)(c)(iii) and s. 84.1(2.32)(c)(iii), so that continued control of Realtyco by Mr. ...

CRA confirmed that, in relation to a sale of the shares of Opco by the two spouses to the Holdco of their adult child for non-share consideration, Realtyco would not be considered a relevant group entity, so that continued control of Realtyco by Mr. ...

26 February 2025 Internal T.I. 2023-0985151I7 F- Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible An individual disposed of all the shares of his corporation to an arm's length purchaser, with the exception of a single preferred share. ...

In addition to numerous transactions to properly package the Segment, the Plan-of-Arrangement transactions included the REIT settling the New REIT, subscribing a modest amount (in the form of a REIT note issued by it to New REIT) in consideration for New REIT units equal in number to the number of outstanding REIT units, distributing a modest amount of cash to a depositary for its unitholders, and selling its units of the New REIT to the unitholders for such cash. ...