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However, s. 181(5)(a), which deems the redemption payment not to be consideration for a supply should apply even if the person is not making the redemption payment in the course of commercial activity. ... Notwithstanding the actual payer, this provision deems the recipient of the supply to have paid and the supplier to have collected GST/HST on that deemed consideration at the time the amount is paid. Therefore, Aco would be deemed to have collected the GST/HST on the deemed consideration for the cancellation compensation and Bco would be deemed to have paid the GST/HST. ...

Question Is the CRA of the opinion that the GAAR applies to this particular series of transactions taking into consideration, among others, the Tax Court of Canada decisions in Evans v. ... CRA Response A file with a similar series of transactions (the “Transactions”) was recently referred to the GAAR Committee for consideration. ... X sold all of his HOLDCO common shares to his children in consideration for promissory notes. ...

This issue is still under active consideration by the CRA. In conducting its review, the CRA must consider the purpose of Form T1135, which is to promote compliance and tax fairness, and to assist the CRA in obtaining information on certain types of assets held by Canadian residents outside of Canada that would otherwise be difficult to obtain. ... If there is consideration attached to the endorsement, in my opinion the profit from it is that of a business as that term is described in section 139(1)(e) [(now defined in section 248(1)]. ... However, the CRA would not generally apply subsection 15(1) solely as a result of the granting of a guarantee where the CRA is of the view that the individual pays the individual’s corporation a reasonable guarantee fee as consideration for the individual’s corporation granting a mortgage guarantee of a personal loan of the individual. ...

For Part 2, in the situation where Amalco transfers the property to another corporation in exchange for consideration that includes shares and makes the s. 85(1) election, the answer comes in two parts because it depends on the agreed amount. ... As part of the spin-out, Holdco transferred shares of Opco with an ACB of nil and a FMV of $1,000 to Newco in consideration for shares of Newco with an ACB and paid-up capital (“PUC") of nil and a FMV of $1,000. Opco then transferred Asset 2 to Newco in consideration for shares of Newco with an ACB, PUC and FMV of $1,000. ...

CanCo would be required to collect tax on the total consideration for the single supply of the call centre service. 3. ... CRA Comments We have given further consideration to this issue and the information you have provided. ... We will bring this issue and situation to the attention of the Department of Finance for tax policy consideration. ...

Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...