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S7-F1-C1 - Split-receipting and Deemed Fair Market Value
The rules allow for the recognition of a gift for income tax purposes in certain circumstances where there is a transfer of property for partial consideration. ... It is generally accepted that a transfer is made by gratuitous title when: the transfer impoverishes the donor to the benefit of the donee and is made without any corresponding consideration; and it is the donor's intention to enrich the donee without receiving any corresponding consideration. ... Therefore, a transfer of property for partial consideration may result in a gift under the civil law. ...
The Tribunal accepted the characterization of the taxpayer’s accounting expert, which was that the parent had made the loan in consideration for the right to receive back the principal plus the right to require a transfer of value between its wholly-owned subsidiaries, which latter right was of no incremental value to it, so that there should be no corresponding recognition of accounting income. ...
9 November 2013- 4:44pm Vivaconcept International- Tax Court finds that voluntarily agreeing to a debt reduction under a proposal does not preclude a bad debt claim for the related GST Email this Content Subject to conditions, the ETA allows both a bad debt claim (under s. 231) for the GST included in a bad trade debt, and for a credit (under s. 232) for the related GST where the consideration for the supply is voluntarily adjusted after the fact and a credit note is issued by the creditor "within a reasonable time" of that adjustment. ...
., no recognition of employment income until exercise) even if the option can be exercised without the payment of monetary consideration. ...
Although from CRA perspective (which you might label as following Marx's labour theory of value), what the casino was mostly getting paid for was its clerical services and the provision of the space, Sharlow JA found that the "commercial efficacy" of the whole arrangement turned on the provision of the cash by the casino, so that the fee was consideration for a single supply of a financial service. ...
("BPO"), is offering to buy the balance of the common shares for cash or BPY units (with the aggregate consideration fixed at approximately 67% units and 33% cash.) ...
17 February 2014- 9:29am Exchangeable shares aren’t dead Email this Content An Australian listed company (Mamba) is proposing to acquire all the shares of a Canadian listed company with the same focus on iron deposits (Champion) for share consideration. ...
., where unrelated vendors receive share consideration from a CRIC (generally, a non-resident controlled Canadian corporation) for the sale of a non-resident corporation The s. 212.3(15)(a) rule, that control of a CRIC does not include control by an upper-tier parent, means that a transfer of the CRIC to that indirect parent can result in a second application of the FAD rules A partnership arguably acts as a blocker, so that Canadian holding companies that are members of a partnership holding a CRIC cannot qualify as qualifying substitute corporations PLOI elections (re accepting imputed interest on debts to exclude them from the FAD rules) are impracticable for cash pooling and other arrangements where intercompany balances are changing every day of the year Neal Armstrong. ...
V, Part III, s. 13 exempts the supply, under a meal plan that is for at least one month, by universities to their students of the right to receive at least 10 meals weekly throughout the meal plan period for a single consideration. ...
Where NR2 issues Note2 in consideration for its acquisition of Note1, which it then promptly contributes to its wholly-owned sub, NR3, it is appropriate to consider that it issued Note2 for the purpose of earning income from its shares of NR3: if it had exchanged Note1 for the issuance of shares of NR3, those NR3 shares clearly would represent the current use of the financing represented by Note2; and it should not make any difference that it instead contributed Note1 to NR3 (per IT-533, para. 25). ...