Search - consideration

Skolrood JA found that there were no reversible errors in the findings of the chamber judge that it was appropriate to “unbundle” the single consideration that GFL charged on a monthly basis to its customers for BC PST purposes: 80% to the non-taxable waste disposal service; and 20% to the taxable lease of the toilets and to the cleaning services provided “to” the toilets. ...

The shareholders transferred their shares of DC on a s. 85 rollover basis to two transferee corporations (the TCs) formed respectively for four of the five siblings and for the second sister, the two types of property were transferred on a pro rata and net asset rollover basis to the two TCs for consideration including TC preferred shares, those preferred shares were redeemed for notes, the TCs immediately established their first taxation year-ends and DC was wound up into the TCs under s. 88(2) (with the redemption notes being extinguished by operation of law and with any remaining CDA account flushed out using s. 88(2)(b)(i)). ...

17 April 2023- 11:23pm Bell Telephone – Tax Court finds that Bell Canada received single supplies of electricity from its Ontario electricity suppliers so that their full charges were subject to provincial ITC recapture Email this Content Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ...

5 February 2025- 8:02am Bell Canada – Federal Court of Appeal finds that Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges Email this Content Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ...

DC then distributed a proportionate share of its net assets to a new subsidiary of TC (Newco) in consideration for preferred shares of Newco, which were redeemed for a note, which was assumed by TC on a Newco winding-up. ...

Canco will sell all of its shares of CFA to Canco’s foreign parent for cash consideration equal to their fair market value and elect under s. 93(1) to the extent of any capital gain. ...

If Amalco sold the residential property within 365 days of the amalgamation on an s. 85(1) rollover basis to a corporation for share consideration, would such election be invalid on the basis that real property inventory could not be “eligible property” pursuant to s. 85(1.1)? ...

CRA indicated: Although s. 116(5.1) will deem the consideration paid by the trust for purposes of s. 116 to be the FMV of the Canadian real estate received, if greater than its ACB, on an administrative basis, CRA will accept the rollover amount under s. 107(2) as representing the proceeds for purposes of issuing a certificate of compliance under s. 116, where there clearly is no risk to the Canadian tax base- which would include situations where the transferred property is Canadian real estate or other property described in s. 128.1(4)(b)(i) to (iii). ...

CRA confirmed that, in relation to a sale of the shares of Opco by the two spouses to the Holdco of their adult child for non-share consideration, Realtyco would not be considered a relevant group entity, so that continued control of Realtyco by Mr. ...

After 12 months, Newco will reduce the PUC of its common shares by an amount equal to the PUC (apparently, all the PUC) of its common shares in consideration for the issuance of eight non-interest-bearing notes, which will not be repayable earlier than at specified successive quarterly intervals, commencing one day after the day of issuance in the case of the 1 st note, and so on, so that the 8 th note is not repayable before the 8 th quarter following such issuance. ...