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3 December 1990 Ministerial Correspondence 903344 F - Shares Issued as Consideration for All or Substantially All of the Assets Used in an Active Business

3 December 1990 Ministerial Correspondence 903344 F- Shares Issued as Consideration for All or Substantially All of the Assets Used in an Active Business Unedited CRA Tags 54.2, 96 24(1) 903344 C. ... You question whether the word "person" includes a partnership, for the purposes of section 54.2 of the Act, where a partnership has disposed of property that consisted of all or substantially all of the assets used in an active business carried on by that partnership to a corporation for consideration that includes shares of the corporation. ...

24 September 1996 Income Tax Severed Letter 9613015 - Gift — consideration

24 September 1996 Income Tax Severed Letter 9613015- Gift — consideration Unedited CRA Tags 118.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Paragraph 3 of Interpretation Bulletin IT-110R2 states that a gift for income tax purposes, is a voluntary transfer of property without valuable consideration. ... No valuable consideration- no benefit of any kind- to the donor or to anyone designated by the donor may result from the payment. ...

29 May 1991 Ruling 910341 F - Dispositions - Absence of Consideration

29 May 1991 Ruling 910341 F- Dispositions- Absence of Consideration Unedited CRA Tags 50(1)(b)(iii), 54 disposition 24(1) This is in reply to your letter dated February 1, 1991 regarding the tax treatment 24(1) The Facts you have presented follow. Facts 24(1) Issues 24(1) Our Comments Interpretation Bulletin IT-460, Dispositions- Absence of Consideration states in Paragraph 4 that "The following occurrences do not constitute a disposition (within the meaning of paragraph 54(c)) of a share of a corporation... ...

7 August 1991 Income Tax Severed Letter - Fair Market Value of Shares Received as Consideration for the Shares Transferred to a Corporation

7 August 1991 Income Tax Severed Letter- Fair Market Value of Shares Received as Consideration for the Shares Transferred to a Corporation Unedited CRA Tags none Dear Sirs: Re: Advance Income Tax Ruling XXX We are writing in response to your letter of July 15, 1991 wherein you requested our views XXX. ... Comments As stated in the reply to question 13 at the 1980 Revenue Canada Round Table, the Department is concerned with the fair market value of the shares received as consideration for the shares transferred to the corporation pursuant to subsection 85(1) of the Income Tax Act (Canada) (the “Act”). ...

7 May 1991 Income Tax Severed Letter - Dispositions - Absence of Consideration

7 May 1991 Income Tax Severed Letter- Dispositions- Absence of Consideration Unedited CRA Tags 54(c), 50(1)(b)(iii) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Facts XXX Issues XXX Our Comments Interpretation Bulletin IT-460, Dispositions- Absence of Consideration states in Paragraph 4 that "The following occurrences do not constitute a disposition (within the meaning of paragraph 54(c)) of a share of a corporation... ...

First Quantum/Inmet -- summary under Unsolicited Bids (corporate)

However, the total cash consideration and First Quantum shares to be provided under the offer and a second-stage transaction will not exceed $2,531,212,776 and 115,901,421 shares (and is fixed at these amounts?). ... The cash consideration will be reduced for any Inmet dividends, with such dividends otherwise being required to be paid to the Offeror. ... "The Offeror currently intends (x) that the consideration offered per Inmet Share under any Subsequent Acquisition Transaction proposed by it would be equal in value to and in the same form as the consideration paid to Shareholders under the Offer, (y) that such Subsequent Acquisition Transaction will be completed no later than 120 days after the Expiry Date and (z) to cause any Inmet Shares acquired under the Offer to be voted in favour of any such transaction and, where permitted by MI 61-101 to be counted as part of any Minority Approval required in connection with any such transaction. ...

4 April 1990 Income Tax Severed Letter ACC9176 - Transfers for Inadequate Consideration

4 April 1990 Income Tax Severed Letter ACC9176- Transfers for Inadequate Consideration 24(1) April 4, 1990 PART II Transfers for Inadequate Consideration 85(1)(e.2); 86(2); 87(4) and 51(2) The corporate reorganization sections in the Income Tax Act contain provisions which impose "penalties" for transfers to or share exchanges with corporations where the value of the property given up exceeds the value of the property received, and "it is reasonable to regard any part of such excess as a benefit that the taxpayer desired to have conferred on a person related to the taxpayer. ...

26 October 1990 Internal T.I. 90M11357 F - Loan Guarantee from Non-resident for No Consideration

26 October 1990 Internal T.I. 90M11357 F- Loan Guarantee from Non-resident for No Consideration Unedited CRA Tags n/a CTF- 1990 Conference Report QUESTION I 69 Withholding Tax- Dividends Paragraph 2(a) of Article X of the Canada-U.S. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F - Meaning of Any consideration received by Donee

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee Unedited CRA Tags 118.1(13) Principales Questions: Est-ce que la « JVM de toute contrepartie reçue par le donataire reconnu pour la disposition du TNA » au paragraphe 118.1(13) se limite à la notion de « produit de disposition » prévue à l’article 54? / Is the "FMV of any consideration received by the donee for the disposition" in subsection 118.1(13) limited to the notion of "proceeds of disposition" in section 54? ... Raisons: La notion de "contrepartie" est plus large. / The notion of "consideration" is broader. ...

19 March 2001 External T.I. 2001-0074075 - Non-share consideration - 85 rollover

19 March 2001 External T.I. 2001-0074075- Non-share consideration- 85 rollover Unedited CRA Tags 85(1)(b)\ Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

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