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12 January 1990 Income Tax Severed Letter AC59272 - Designations by Testamentary Trusts

Your comments will be taken into consideration during this review. Yours truly, for Director Financial Industries Division Rulings Directorate ...

6 November 1989 Income Tax Severed Letter ACC8495 - Source Deductions Waivers

Chris Martin of Consumer and Corporation Affairs Canada for your consideration and direct reply. ...

29 November 1989 Income Tax Severed Letter ACC8426 - Transmission of Documents

Jolie of your office, we are forwarding for your consideration and reply the yellow file folder containing 24(1) letter of October 31, 1989 addressed to the Honourable Otto Jelinek. ...

2009 Ruling 2009-0338731R3 - Public spin-off butterfly

(ee) DC loaned funds to Bankco, Bankco used the loaned funds to subscribe for XXXXXXXXXX additional common shares of Subco I Holdco for cash consideration and Subco I Holdco subscribed for XXXXXXXXXX additional common shares of Subco I for cash consideration. ... As consideration for the Distribution Property so transferred by DC to Spinco, Spinco will issue to DC XXXXXXXXXX Spinco Special Shares having an aggregate Spinco Special Share Redemption Amount equal to the fair market value of the Distribution Property at the time of the transfer, less the fair market value of any non-share consideration paid by Spinco in consideration for the Distribution Property. ... The amount of any non-share consideration paid by Spinco in consideration for the Distribution Property will not exceed the fair market value of the Distribution Property. ...

2007 Ruling 2006-0218911R3 - 132.2 reorganization with an internal butterfly

The Trust will convey its New Preferred Shares Series 3 of Opco to Opco #3 in consideration for common shares of Opco #3. ... In consideration, Opco #3 will assume the Fund Notes and will issue Opco #3 Preferred Shares. ... Unitholders will receive no consideration other than Fund Special Units on the redemption of the Class A Shares and the Fund will receive no consideration other than Units on the redemption of the Class B Shares. 61. ...

2005 Ruling 2005-0113301R3 - Butterfly

As sole consideration, Transferee 1 will issue to Trust1 XXXXXXXXXX Common shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC so transferred to Transferee 1. 29. ... As sole consideration, Transferee 3 will issue to Sib3 XXXXXXXXXX Common shares of its capital stock having a fair market value equal to the fair market value at that time of the shares of DC so transferred to Transferee 3. 37. ... Each of the 5 Transferees will subscribe for one (1) Common share of its respective SubCo for cash consideration of $XXXXXXXXXX. ...

1998 Ruling 9825963 - INTERNAL REORGANIZATION

As consideration for the transfer, XXXXXXXXXX will receive an increased partnership interest. 49. ... As sole consideration for the transferred XXXXXXXXXX Common Shares, Newco 1 will issue to XXXXXXXXXX. ... As sole consideration for the transferred XXXXXXXXXX Common Shares, XXXXXXXXXX will issue to XXXXXXXXXX Common Shares. ...

2020 Ruling 2020-0853221R3 - Split-up butterfly: investment company

These shares have a non-cumulative dividend right of up to XXXXXXXXXX% per annum on the consideration received by DC upon issuance of the shares. ... Sibling 1 will subscribe for 100 TC1 Common Shares for aggregate consideration of $XXXXXXXXXX. 16. ... Sibling 2 will subscribe for XXXXXXXXXX TC2 Common Shares for aggregate consideration of $XXXXXXXXXX. 19. ...

Societe d'Ingenierie Cartier Limitee v. The Queen, 86 DTC 6025, [1986] 1 CTC 166 (FCTD)

Cartier claims that the amount was received as consideration for Cartier agreeing to discontinue its present and any future legal actions against Kruger, including its potential action against Kruger for damages to its reputation, and for giving a full and final release to U.S. ...

Maréchaux v. Canada, 2010 DTC 5174 [at at 7315], 2010 FCA 287, aff'g 2009 DTC 1379 [at 2095], 2009 TCC 587

Friedberg, 92 DTC 6031 (FCA) at 6032: … 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. ...

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