Search - consideration

11 February 2018- 10:58pm Consideration should be given to avoiding an immediate liquidation of an RESP on death Email this Content A registered education savings plan will form part of the estate of a deceased sole or last subscriber to the RESP. ...

20 October 2015- 12:24am CRA finds that a commitment fee earned by the assignor of a loan is consideration for the loan made by the assignee for HST purposes Email this Content Exempt financial services include (in para. ...

24 July 2014- 3:14pm First Quantum acquisition of Lumina uses tainting nominal cash for the share consideration alternative, and provides for cashless option surrenders Email this Content Lumina Copper shareholders can elect to receive First Quantum shares or cash for the acquisition of their shares subject to proration to keep the overall cash/share mix essentially fixed.  ...

22 March 2015- 8:25pm Majority shareholders of Wheels Group agree to bear the full brunt of any proration required to constrain the overall mix of cash and share consideration paid under a Radian Logistics acquisition Email this Content Radian Logistics, a listed Delaware corporation, is proposing that its new ULC subsidiary acquire all of the shares of Wheels Group for cash or Radian Logistics shares under a Plan of Arrangement. ...

31 May 2016- 9:08am CRA considers that the s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Email this Content FA1 transfers all of its shares of FA2 to another non-resident subsidiary of FA1, viz., a non-share corporation (“FA3”), as a capital contribution, i.e. no new member interests are issued by FA3. ...

22 July 2016- 12:24am CRA confirms that the s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Email this Content FA1 transfers all of its shares of FA2 to another non-resident subsidiary of FA1, which is a non-share corporation (“FA3”), as a capital contribution, i.e. no new member interests are issued by FA3. ...

30 May 2018- 12:29am CRA finds that full compensation to a customer who returned goods precluded access to the GST/HST consideration-adjustment rule Email this Content CRA accepts that ETA s. 232 generally applies where a supplier refunds the purchase price of goods that are returned to it by its customer, so that there is no need for the customer to charge GST/HST on the refund payment. ...

28 March 2021- 10:29pm CRA indicates that it will only grant a request in a objection to confirm a GST/HST assessment without consideration in exceptional circumstances Email this Content ETA s. 301(4) provides "where, in a notice of objection, a person who wishes to appeal directly to the Tax Court requests the Minister not to reconsider the assessment objected to, the Minister may confirm the assessment without reconsideration.” ...

2 August 2013- 2:22pm Inter Pipeline management get rollover treatment on their $340 million consideration for agreeing to internalize management Email this Content Inter Pipeline, which is a TSX-listed LP, is being converted into a public company under an Alberta Plan of Arrangement.  ...

11 July 2025- 12:05am CRA indicates that the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible Email this Content An individual agreed to sell all the shares of a corporation except that he also agreed with the purchaser that he would retain a preferred share in that corporation on which he would receive a dividend equal to a percentage of any damages award to the corporation in its action against a 3 rd party for lost profits – but that if the law suit was unsuccessful, he would reimburse the corporation for certain of its legal fees. ...