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18 November 2014- 10:22am Vocalspruce – English Court of Appeal broadly interprets a deeming provision Email this Content A UK sub (Vocalspruce) acquired zero coupon notes from its UK parent in consideration for its issuance of shares, and credited the discounts on the notes to its share premium account when received, with the targeted result that those discounts were tax-exempt. ...
Accordingly, they transfer their FA shares to Can Holdco (their sister) on a purported s. 85 rollover basis in consideration for Can Holdco prefs with a fair market value equal to the ACB of the transferred shares (rather than their higher FMV). ...
CRA also ruled that the provision by the property LP of a guarantee of construction loans to the development partnership in consideration for annual guarantee fees did not represent the carrying on by the property LP of a business (so that the guarantee agreement viewed as a potentially valuable right to the fees did not represent non-portfolio property). ...
14 April 2013- 7:42pm CRA finds that the HST/GST credit note mechanic was not available in a returned goods situation Email this Content The credit note rule in s. 232 provides a mechanism for reducing a Canadian registrant’s GST or HST remittance obligations when it reduces the consideration for a supply. ...
Intrepid Mines, whose only significant asset is US$165M of cash, is proposing to offer to purchase back its outstanding shares at a stipulated price, subject to an aggregate cap of 2/3 of its cash, and to then acquire all the shares of another listed Australian company (Blackthorn) under an Australian scheme of arrangement in consideration for Intrepid shares, so that those Intrepid shareholder who do not tender to the buyback will now have an indirect investment in a Zambian copper project. ...
Ignoring convoluted transactions pursuant to which they get rid of those non-voting common shares to Dixie Energy Trust, they then simply transfer that cash under the plan of arrangement to the Trust in consideration for Trust units. ...
The effect of the increased sales consideration was to reduce the related new housing rebate on some of the sales. ...
18 May 2015- 8:13pm Le Groupe Jean Coutu – Quebec Court of Appeal finds that rectification is not available to reverse an adverse tax consequence (FAPI) that the parties did not think about Email this Content The taxpayer implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. sub, that overlooked FAPI considerations – so that interest on a loan made by the sub back to Canada was included in the taxpayer’s income. ...
The usual single-supply doctrine applies so that, for example, a charge for ferrying a plane from another city to the embarkation point for the charter flight and various airport charges which the carrier has no choice but to incur will be part of the consideration for the passenger transportation service provided by the carrier. ...
., she rejected the proposition that the obligation of the trusts to make the special distributions was part of the consideration received by the manager. ...