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14 February 2001 CBA Roundtable

Therefore, this is not a single consideration and precludes the use of section 139. ... As a result of the election, the supplies made between the corporations are deemed to be made for nil consideration. ... If the horse wins a race, pursuant to subsection 188(2) of the ETA, the consideration is deemed not to be consideration for a taxable supply. ...

9 October 2015 APFF Financial Strategies and Financial Instruments Roundtable

The rules stipulated in subsection 85(1) permit a taxpayer to transfer on a rollover basis an “eligible property” to a taxable Canadian corporation for consideration that includes shares of the capital stock of the corporation. ... The question of whether a loan made by a beneficiary or the assumption by the beneficiary of a hypothec constitutes consideration for the acquisition of an interest in the trust is a question of fact which cannot be determined before an examination of all the facts and relevant documentation. ...

Subsection 2(1) - Commentary

No tax on: mortgages leases with remaining term including extensions or renewals provided for in the lese or related documents of under 50 years transfer to nominee for nil consideration if no relevant previous beneficial transfers transfers on amalgamations (LTT-3) Exemptions for unregistered dispositions: de minimis partnership transactions (5% increment per year), but not where transferee is trust or partnership transfer or issuance of mutual fund units transfers between affiliated corporations (if timely deferral application and no subsequent registration in group (s. 3(13.1))) butterfly reorganizations employee relocation plans TOR See MLTT Rates and Calculation Toronto Municipal Code, C. 760 City of Toronto imposes a tax (over and above Ontario tax) on the same base as Ontario 0.5% on first $55,000 of value of consideration; 1.0% on next $195,000; 1.5% on next $150,000; 2.0% on excess over $400,000; Plus an additional 0.5% on property with one or two family dwellings to extent the consideration exceeds $400,000 Same as Ontario plus some additional exemptions in s.760-14, e.g., for Toronto municipal bodies QC Act Respecting Duties on Transfers of Immovables Municipalities are obliged to levy their own duties on the transfer of an immovable. ... Calculated on the "basis of imposition:" the greatest of: consideration furnished; price in deed; and market value for municipal tax purposes (i.e., municipal roll value multiplied by designated factor): 0.5% of basis of imposition up to $50,000 1.0% on the next $200,000 1.5% of excess However, since 2017, municipalities have been authorized to increase the marginal rate for value in excess of $500,000 to 3.0%, and some have done so. ... No tax on mortgages leases with unexpired term of 21 years excluding renewals (s. 3(t)) No tax on changing the registered name reflecting an amalgamation PEI Real Property Transfer Tax Act (see also Lands Protection Act) Tax is triggered only on an acquisition by deed (s. 3(1)) 1% of the greater of the consideration for the transfer and assessed value No payment for mortgages given to banks, trust companies and other financial institutions acting in the ordinary course of businessRegistered transfers between wholly-owned corporations are exempted.No tax on registration on title of notice of an amalgamation. ...

17 May 2022 IFA Roundtable - Draft CRA Written Response

Whether a particular apportionment of the consideration paid is reflective of the actual payments described in the exemption under subparagraph 212(1)(d)(vi) depends on the legal nature of what is being provided under the mixed contract, the relationship between the parties and the facts of the particular situation including the commercial reality of the parties and the consideration paid in these circumstances. In determining if an apportionment provided under a mixed contract is reflective of the obligation of the parties under subsection 212(1), consideration would be given, amongst others, to the terms of the mixed contract and to whether the parties have divergent interests in respect of this apportionment. ... Such discretionary relief is granted on a case-by-case basis, by the appropriate delegated authority, pursuant to subsection 220(2.01), with due consideration to all of the relevant circumstances. ...

Paragraph 212.3(10)(b) - Commentary

Thus, a transfer of property by the CRIC to the subject corporation is an investment for such purposes even if the CRIC does not receive any consideration, such as the issuance of shares or debt, of the subject corporation. ... Example 10b-A (conferral of benefit) CRIC transfers intellectual property to a non-resident subsidiary in consideration for an obligation to pay a royalty. ... For example, the transfer by a CRIC of shares of one non-resident subsidiary to a second non-resident subsidiary for nominal share consideration would generally qualify for rollover treatment under s. 85.1(3), so that s. 212.3(18)(b)(ii) would deem there to be no resulting investment by the CRIC in the second non-resident subsidiary notwithstanding that it likely would be considered to have conferred a benefit on it. ...

Paragraph 88(4)(b) - Commentary

Suppose that shares of Target are acquired in consideration for shares of a parent (Pubco) of the acquirer of Target (Bidco). ... The question arises as to whether such parent (Amalco) can satisfy the requirement that the shares of Pubco were received by the Target shareholders in consideration for their shares of Amalco – when in fact, the Pubco share were instead issued in consideration for the acquisition of the shares of a predecessor of Amalco, namely, Target. ... A similar issue and resolution arises under s. 88(1)(c.4)(i) where the bid consideration is shares of the parent rather than its shareholder. ...

3 December 2019 CTF Roundtable

A transfers his shares of the capital stock of Opco 1 to Opco 2 in consideration for a note Paragraph 84.1(1)(b) applies and a dividend is deemed to have been paid by Opco 2 to Mr. ... Under s. 212.1(6)(b)(ii), each non-resident beneficiary will be deemed to have received consideration other than the shares of the purchaser corporation, and that consideration received will, again, be equal to the proportion of their interest in the trust. ... Z taking into consideration the application of the deeming rule in subparagraph 120.4(1.1)(b)(ii)? ...

25 November 2021 CTF Roundtable - Official Responses

It looks like the share consideration to be received by a shareholder of a predecessor corporation may be reduced by a repurchase by Parent of shares issued as consideration for shares of a predecessor corporation for $1 and the value of the shares repurchase would correspond to the indemnity claim made by the Parent. ... In this situation, the reduction in value of the shares held by the Target shareholders is made as consideration for the settlement of the indemnity claim. ... Accordingly, the surrender by the Taxpayer of their common shares of US Pubco as consideration for the receipt of common shares of US Pubco Spinco does not constitute an “eligible distribution” contemplated by section 86.1. ...

25 November 2021 CTF Roundtable

Would this be consideration other than shares of Parent for purposes of subsection 87(4)? ... Scenario 2 Prud'Homme: In this situation, of course, the reduction in value of the shares held by the Target shareholders is made as consideration for the settlement of the indemnity claim. ... The present scenario deals with an exchange – there is a disposition of the shares of US Pubco and, as consideration, shares of Spinco are received. ...

17 May 2022 IFA Roundtable

By “reasonable and realistic,” the CRA means that it should be reflective of the actual consideration paid for the copyright described under the exception in s. 212(1)(d)(vi). ... Whether a particular apportionment of the consideration paid is reflective of the actual payments described in the exemption under s. 212(1)(d)(vi) depends on the legal nature of what is being provided under a mixed contract. The relationship between the parties and the facts of the particular situation, including the commercial reality of the parties and the consideration paid, would be considered. ...

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