Search - "Contribution of Property"

In finding that the supplies of T-shirts by the charity were not exempt, with HST or GST applying on the consideration of $X for each supply of a T-shirt, CRA stated:...where the charity provides the person making the contribution with property or a service of more than nominal value that served as an inducement to make the contribution, then for ETA purposes, the amount of the contribution is not regarded as a gift but as consideration for the supply of the property or service given in return by the charity. ...

Although no rulings were given on the paid-up capital of the LLCs, the description of the "Shares" of the Delaware LLC ("LLC2") to be contained in the LLC Agreement- and similarly for California- stated: "Capital" of Shares is the aggregate of all amounts paid to LLC 2 and the monetary value at the time of contribution of property contributed to LLC 2 (in each case including amounts paid or contributed prior to USco 2's conversion to LLC 2) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 2 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 2 Agreement. ...

In finding that the supplies of T-shirts by the charity to the donors were not exempt, with HST or GST applying on the value of $X for each supply of a T-shirt, CRA stated:...where the charity provides the person making the contribution with property or a service of more than nominal value that served as an inducement to make the contribution, then for ETA purposes, the amount of the contribution is not regarded as a gift but as consideration for the supply of the property or service given in return by the charity. ...