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A similar “later of” concept should be employed federally and, given that many taxpayers operate in Québec, consideration should be given to coordinating deadlines. ...

Consideration should be given to ways in which the rules canbe further adjusted to accommodate circumstances such as a joint-venture scenario in which each joint venturer funds its contribution to the venture mostly with loans from what is an eligible group corporation respecting it, with such loans being proportionate to their respective interests. ...

On January 1, 2015, FA provides services to Canco in consideration for a fee. ...

The Tax Court found that the classroom teaching and Materials were all essential parts of the courses and generally purchased for a single consideration, and, therefore, concluded that SBA made bundled supplies of exempt educational services to students…. ...

Michael Coburn, "Practical Strategies for Dealing with the Restrictive Covenant Provisions", 2014 Conference Report (Canadian Tax Foundation), 8:1-29-- summary under Paragraph 56.4(3)(b) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(3)- Paragraph 56.4(3)(b) S. 56.4(3) as a counter to s. 68(c) (pp.21-22) [S]ubsection 56.4(3) contains provisions that effectively allow an amount received as consideration for granting a restrictive covenant to be characterized as either proceeds of disposition (presumably allowing for capital gains treatment in the hands of the recipient) or an eligible capital amount. ...

On the other hand, it may be interpreted on the basis of factual or economic substance considerations. ...

As indicated in the example, there is nothing offensive about simply swapping property in a TFSA for cash or other consideration of equal value in the holder's RRSP. ...

Fourth and finally, the Department of Finance, which drafts Canada's tax laws for Parliament's consideration, has clearly endorsed the notion that U.S. ...

[O]ne issue is that the initial issuance of exchangeable shares in consideration for Target shares and the final exchange of the exchangeable shares for Foreign Parent shares may be regarded as part of the same series….The final exchanges could be many years after Target is acquired and it would be difficult, if not impossible, to predict or control relative fair market values….The Joint Committee's submission on this point was not addressed…. ...

. … the need for the documents should be balanced by the costs and administrative burdens, particularly where this process suggests the creation of documents that would not otherwise be prepared or referred to in the absence of tax considerations. ...