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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. ...

A is an advisor or a promoter in respect of the sale of the financial product (notably whether she acted in a manner described in the definition of “advisor” or “promoter” in s. 237.3(1) in respect of the sale of the financial product); the terms of the sale of the financial product and the series of transactions, of the financial product, and of the consideration received by Ms. ...

Proposed transactions The Trust will transfer its ACo common shares to a resident corporation newly-formed by it (“Newco”) in consideration for notes and Newco preferred shares, electing under s. 85(1). ...

The estate will transfer, to a “Newco” formed by it under the CBCA, Class A preferred shares of Holdco in consideration for a demand note ("Note 2") of Newco and a Class A share of Newco (apparently, its only issued and outstanding share), electing under s. 85(1). ...

Fco makes a PUC distribution to the trust by distributing a note of a subsidiary in an amount sufficient for the trust to pay the tax on the above taxable dividend. the father of CC4 settles a new trust for the exclusive benefit of CC4, with the old trust transferring its Class Z shares of Fco to the new trust for no consideration, and with the new trust not electing out of the application of para. ...

Proposed transactions The estate will transfer to a corporation newly incorporated by it (Newco) its Class A and Class B shares of Holdco in consideration for Note 1 (plus some Newco Class A voting and participating shares) and Note 2 (plus some Newco Class B voting redeemable preferred shares), respectively, electing under s. 85(1). ...

However, the Directorate indicated that “to allow a taxpayer who has made a misrepresentation to use subparagraph 152(4)(a)(i) to reduce the amount of tax assessed would be inappropriate,” in light of various considerations. ...

Pursuant to a new services agreement with Foreignco, Canco will provide “Computer Services” and “Other Support Services” to Foreignco and other non-resident members of the group in consideration for reasonable fees. ...

The Directorate also stated: Consideration was given to whether paragraph 8 of Article 10 of the Treaty could apply only to dividends paid on a particular tranche of shares (i.e. the initial acquisition of shares or a subsequent acquisition of shares resulting in 10% beneficial ownership, either directly or indirectly). ...