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He went on to indicate that, to determine the character of the single supply, it was necessary to determine “which element caused the payment of the consideration,” and then stated that in light of the importance of the professional services provided by Dr. ...

However, CRA 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. ...

Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) applies to shares issued as part consideration for shares of a different class transferred to the corporation on a dirty s. 85 exchange 5 November 2003 Internal T.I. 2003-0037977 F- FRAIS POUR ANNULER UNE OFFRE D'ACHAT Also released under document number 2003-00379770. ...

6 June 2023- 10:55pm Finance suggests changing the transfer-pricing rules to focus on transactions’ "economically relevant characteristics" Email this Content The consultation paper of Finance on the transfer pricing rules includes draft legislation that is under consideration. ...

CRA indicated that the ETA s. 181 coupon rules would to some extent apply, so that: On the acceptance of the points (viewed as “coupons”) by Bco or the dealer as part consideration for the taxable supply of the widgets, they are deemed to have collected tax equal to the GST/HST that would have been collected had the points not been collected (i.e., equal to the tax fraction of the points’ value). ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-06-07 11 June 2002 External T.I. 2001-0104075 F- DEDOMMAGEMENT Income Tax Act- Section 54- Adjusted Cost Base damages award not part of cost if subject to an appeal Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) damages award not recognized until appeal thereof heard 17 June 2002 Internal T.I. 2001-0111717 F- BFT ET CONSTRUCTION MAISON EN USINE Income Tax Act- Section 125.1- Subsection 125.1(3)- Manufacturing or Processing- Paragraph (c) fabricator of manufactured homes was not excluded for engaging in “construction” 18 April 2002 Internal T.I. 2002-0118827 F- DEBENTURES CONVERTIBLES see also 2002-0130177 F Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) no s. 20(1)(f)(ii) deduction on conversion of convertible debentures notwithstanding attempt in resolution to fix the issued shares’ stated capital at their market value Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital PUC of shares issued on debenture conversion equal to consideration stated in debenture indenture and in financial statements, rather than the FMV of shares stated in resolution Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Owen J rejected the taxpayer’s submission that she was not liable under s. 160(1) because she had provided full consideration for the transfer through her agreement to marry CC and care for him. ...

Shortly after the acquisition by Bidco, there was a transfer of most of the Target holdings to a “JV Co” initially owned by the Taxpayer but with Pubco being transferred ½ of the shares of JV Co in consideration for the Bidco cash funding it had earlier provided. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-03-01 5 March 2002 Internal T.I. 2001-0102757 F- PERTE FINALE Income Tax Act- Section 54- Adjusted Cost Base cost of moving rental building off land for subsequent sale, in order to construct parking lot and create more space for existing rental buildings, was addition to ACB of land Income Tax Regulations- Regulation 1102- Subsection 1102(1)- Paragraph 1102(1)(c) a rental building that was acquired with a view to then moving it off the subjacent land and then selling it, was not a depreciable property 6 March 2002 Internal T.I. 2001-0108587 F- AIDE A DOMICILE DE LA SAAQ Income Tax Act- Section 152- Subsection 152(4) refunds not issued beyond Objection period based on favourable judgment rendered to another taxpayer Income Tax Act- Section 3- Paragraph 3(a) in cases similar to Maurice, parent caregivers may be exempted on compensation received 2002-02-15 7 March 2002 External T.I. 2001-0106275 F- BOURSE D'ETUDES ET DE PERFECTIONNEMENT Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) general discussion regarding foreign internship sponsored by Foreign Affairs 4 March 2002 External T.I. 2001-0106325 F- ALLOCATION POUR UNE AUTOCARAVANE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) allowance for motorhome must be for its use in travelling rather than as accommodation to come within s. 6(1)(b)(vii.1) Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(r) motor home is not an automobile and thus not within s. 18(1)(r) 1 March 2002 External T.I. 2002-0118215 F- ACTIONS EMISES GRATUITES AUX EMPLOYES Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) s. 7 rules applicable to shares issued for no consideration to employees Income Tax Act- Section 7- Subsection 7(1.1) s. 7(1.1) continues to apply after issuing employer ceases to be a CCPC 8 March 2002 External T.I. 2002-0123095 F- TRANSFERT- CREDIT DEFICIENCE Income Tax Act- Section 118.2- Subsection 118.2(3) overview of requirements for transfer of severe impairment credit to parent ...

Corco purchased all of the appellant’s shares in consideration for issuing a $600,000 demand promissory note. ...