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" Thus, provided the agreement to be loyal for the average length of a marriage is considered to be on account of future services, the s. 20(1)(m) reserve should be available even if the consideration is considered to be included in income under s. 56.4(2). ...

These assets would then be tested for an eligible purpose. 1.63.2 In situations such as those in ¶1.63.1 but where the debt represents only partial consideration for the share acquisition, if some assets do not meet the purpose test, the taxpayer may adopt a flexible approach in linking the debt to the eligible assets formerly held by the acquired corporation.... ...

20 March 2016- 8:08pm CRA confirms that the status of a location as a “place of amusement” for purposes of the public sector body exemption may be determined on an event-by-event basis Email this Content Charges for events by a charity which otherwise might be exempt from GST/HST generally will be taxable if they are characterized as admissions to a “place of amusement” for more than nominal (over $1.00) consideration (and they do not come within an exemption for non-recurring fund-raising). ...

Here, similar considerations (deferral v. absolute reduction in total tax) govern the choice between accessing safe income or sticking with capital gains treatment. ...

The Quebec Court of Appeal found that, in light of considerations of procedural fairness, the Quebec equivalent of ITA s. 165(3) should be read as if it contained the additional bolded words noted below: [T]he Minister shall … reconsider the assessment and … make a reassessment, and send the Minister's decision to the person by mail and to its designated representative, if any. ...

Turgeon) agreed to sell some preferred shares of the CCPC to a newly formed Holdco of its comptroller (“Hélie Holdco”) in consideration for a promissory note bearing interest at 4% and which was to be repaid over a number of years out of dividends or redemption proceeds received by Hélie Holdco from the CCPC. ...

The U.S. tax disclosure indicates a risk of the Early Consent shares being treated as a taxable consent fee, whereas the Canadian disclosure is clear that they are part of the exchange consideration. ...

Summaries of Marie-Andrée Beaudry and Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations," Draft 2015 Annual CTF Conference paper under s. 80(13), s. 80(4), s. 80(3), s. 20(1)(c), s. 80(1)- commercial debt obligation, s. 18(1)(e), s. 224.1, s. 222(2), s. 80(2)(h). ...

The shares of Subco2, which might be a significant subsidiary of DC, are split 50-50 between TC1 and TC2 on the butterfly, then TC1 sells its shares of Subco2 to TC2 for FMV consideration. ...

In rejecting a submission that such additional fees are part of the consideration for a single supply of the ultimate permits, CRA noted that “the provision of property and/or services by two or more suppliers generally indicates that multiple supplies are being made, even if the various supplies are provided together,” and that “many of the fees identified are payment for a separate supply, e.g., approval of a plan amendment or a condominium conversion.” ...