Search - consideration

Sub2 will transfer its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and a non-interest bearing promissory note (the “Sub1 Note”), jointly electing under s. 85(1). ...

Sub2 will transfer its interest in Partnership to Sub1 in consideration for Sub1 Preferred Shares and a non-interest bearing promissory note (the “Sub1 Note”), jointly electing under s. 85(1). ...

Respecting Scenario 2: [A]s is apparent from Duha, the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement. ...

19 January 2018 External T.I. 2017-0683501E5- Flow-Through Shares-- summary under Section 38.1 Summary Under Tax Topics- Income Tax Act- Section 38.1 general paraphrase A taxpayer transfers capital property under s. 85(1) to a resource company in consideration for publicly listed common shares (the “Share”) of the resource company, and donates the Shares to a qualified donee. ...

Acquisition and wind-up of Lossco A number of years later, Taxpayer will purchase all of the Lossco shares for nominal consideration and wind-up and dissolve Lossco (which is not expected to have any assets). ...

The Partnership subsequently transferred all of its assets, including the shares of the Creditor Affiliate, to a newly formed wholly-owned U.S. subsidiary of Partnership (the “Debtor Affiliate”), the consideration for which included the Debtor Affiliate assuming the Partnership’s liability to repay the Loan and to pay the accrued but unpaid interest thereon (the “Accrued Interest”) to the Creditor Affiliate. ...

CCRA confirmed 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). ...

17 December 2003 Internal T.I. 2003-0047727 F- Right of Use-Deemed Trust-- summary under Subsection 105(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(1) no s. 105(1) benefit from personal use of personal-use property of a trust 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. ...

It subsequently sold its Lossco shares to a profitable wholly-owned subsidiary ("Profitco") for nominal cash consideration, with Lossco then being wound-up into Profitco under s. 88(1) so that Profitco could then access Lossco's non-capital losses pursuant to s. 88(1.1). ...

27 May 2004 External T.I. 2003-0031231E5 F- Actions visées par règlement-gel successoral-- summary under Subclause 6205(2)(a)(ii)(A)(II) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2)- Paragraph 6205(2)(a)- Subparagraph 6205(2)(a)(ii)- Clause 6205(2)(a)(ii)(A)- Subclause 6205(2)(a)(ii)(A)(II) trusts in which nieces and nephews were beneficiaries nonetheless were deemed NAL for purposes of satisfying Reg. 6205(2)(a)(ii)(A)(II) Three brothers (A, B and C), who were the equal common shareholders of ABC, each effected an estate freeze in favour of a discretionary trust for the benefit of himself, his wife and their descendants, so that their common shares of ABC were converted into preferred "freeze shares and new common shares (assumed to be prescribed shares) were issued for nominal consideration to the respective family trusts (Trusts A, B and C). ...