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Subsequently to the transactions considered in 2017-0735771I7, ACo transferred its shares of BCo to DCo for consideration including shares of the capital stock of DCo pursuant to subsection 85.1(3) of the Act. ...

(a) After quoting Friedberg (“a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor,”), CRA indicated that where, as appeared to be the case here, the trust has no discretion as to whether to make the payment to the charity, the payment does not qualify as a gift and thus, is ineligible for the donation tax credit. ...

A”) transferred his catering business to a newly incorporated corporation (“Opco”) in consideration for Opco preferred shares, with a family trust (“Trust”) subscribing for common shares. ...

Proposed transactions The Continuing Shareholders and key employees will transfer their Pubco Shares to newly-incorporated Newco under s. 85(1) in consideration for common shares (or common shares and notes, in the case of the key employees). ...

CRA stated: Based on the fact that contributions were made to the SMSF by an employer of the taxpayer’s ex-husband in consideration for his employment services and that the sole purpose of the SMSF is to provide retirement benefits to its members, it is reasonable to conclude that the SMSF is a pension plan for purposes of the Act. ...

The estate will transfer to a newly-incorporated corporation (“Newco”) its Class E shares of Holdco in consideration for Class A voting participating shares of Newco, electing under s. 85(1) (no price-adjustment clause). ...

After referring to the employee benefit plan (“EBP”) definition in s. 248(1), CRA noted: Generally, a plan will be considered to be a pension plan (irrespective of whether it is registered under the Act) “where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee’s retirement.” ...

In some circumstances involving smaller FTS offerings, the Issuer may not retain an Underwriter (to whom it otherwise would have paid a fee in the range of 3 to 6% of the FTSs subscription price (an “Offering Assistance Fee”) to assist in finding Investors and, instead, the Promoter will provide such assistance in consideration for an Offering Assistance Fee. ...

AE Trust will transfer its common shares of Aco and Bco on a s. 85(1) rollover basis to a corporation newly-incorporated by it (Newco) in consideration for two notes of Newco and preferred shares whose redemption value is nominal subject to the operation of a price adjustment clause. ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 8, 2021-0899701C6 F- Post-mortem planning- Pipeline-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) pipeline transaction can be structured to access hard ACB In order to implement pipeline planning, the estate of an individual ("Estate") generally incorporates a new corporation ("Newco") to which it sells shares of a private corporation ("Target"), with or without a tax rollover, in consideration for shares of Newco (the "Shares") or a note issued by Newco ("Note").Newco will remains in existence for at least one year before being merged with Target to form Amalco, whose assets are gradually used to redeem the Shares or Note. ...