Search - consideration

In Year 1, Holdco1 transfers assets to Opco on a rollover basis in consideration for preferred shares. ... Opco redeems the preferred shares held by Holdco1 in consideration for the $500 of cash, such that there are no assets remaining in Opco afterwards except for the goodwill. ... Realization of gain accrued at the time of acquisition Assume a transfer of property with an accrued gain to a corporation on a rollover basis in consideration for preferred shares. ...

Headquarters will generally in turn refer the matter to the GAAR Committee for consideration. ... Thus taxpayers should be assured that when the application of the GAAR is considered, all their arguments will have received careful consideration. ... The CRA will take your suggestion under consideration. CRA Response (b) The Canadian FTC is dependent on a confirmed final tax liability with the foreign tax authority and the supporting documents requested are proof of that confirmed final tax liability. ...

Each case could warrant different considerations based on its particular fact situation, and it may be settled differently. ... Can the CRA confirm that a subsequent transaction to ‘use’ the note or other property (including cash) received as consideration for a share redemption, such as the transfer of the note to Newco in CRA document # 2015-0604521E5, is a necessary trigger for a GAAR determination with respect to paragraph 55(3)(a)? ... Taking into consideration the input of stakeholders, the CRA further pursued its analysis of the legislative system requirements needed to implement the RTPP. ...

(c)(ii)(C) of the “total charitable gifts” in s. 118.1(1) was added to allow for the inclusion, in a trust’s total charitable gifts of the eligible amount of a gift made by the it in a s. 104(13.4)(a)-shortened taxation year, CRA quoted Friedberg (“a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor,”), and indicated that at common law there is a gift if the taxpayer has donative intent and: there was a voluntary transfer of property to a qualified donee; the transferred property was owned by the donor; and no benefit or consideration flowed to the donor. and that whether a payment by an alter ego trust to a registered charity is a charitable gift by it or a distribution of income or capital to a beneficiary turns on the trust-deed wording and the intentions of the trustee in making the payment. ... It is a question of fact as to whether the husband and wife could be considered to satisfy the excluded business test for a particular year or continue to meet such test thereafter, as consideration must be given to the ongoing nature and labour requirements of the corporation’s business. ... In general, for the purposes of determining whether an amount would have been an excluded amount in respect of a deceased spouse or common-law partner of a specified individual had it instead been included in their income, consideration needs to be given to all their facts and circumstances in the applicable taxation year, including any shares of the corporation owned by them. ...

Although s. 107(2) is not applicable to this situation, consideration could be given to whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could apply to allow the property to be transferred on a tax-deferred basis. We have not considered the application of these provisions in this situation, but note that the determination of whether they could be applicable would require consideration of all the relevant facts and circumstances, including the terms and conditions that apply in respect of both Trust and New Trust. ... At a particular time on November 1, 2020, ACo purchases for cancellation all of its shares owned by BCo for consideration that exceeds the aggregate paid-up capital of those shares, resulting in ACo being deemed to pay a dividend, as computed under subsection 84(3) (“Deemed Dividend”) at that time, to BCo. ...

A vendor (Vendor) sells all of its shares of a corporation (Target) to a purchaser corporation (Purchaser) in consideration for, exclusively, shares of the Purchaser. ... That same paragraph indicates that for a service business, the place where the services are performed should be given consideration. ... Broadcast Rights Payments are consideration for a right to which paragraph (f) of the definition of “copyright” in the Copyright Act applies, i.e., the right to communicate work to the public by telecommunication. ...