Search - consideration

In this regard, the Act does not specify whether the "FMV of any consideration … received by the donee for the disposition” of the NQS refers to the specific concept of "proceeds of disposition" provided for in s. 54 or, more generally, to any consideration received in connection with such disposition, including the portion of such consideration that would constitute a deemed dividend under s. 84(3), in the event of a redemption of shares. ... The word "consideration" is not defined in the Income Tax Act. ... The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

Timg tax becomes payable when consideration is comprised of a forgivable loan Summary of Question By virtue of s. 168 ETA, tax is payable on the earlier of the day the consideration for the supply is paid and the day the consideration for the supply becomes due. ... CRA Comments When an amount is payable as consideration for a taxable supply, tax is payable on the value of the consideration on the earlier of the day the consideration is paid and the day the consideration becomes due, pursuant to subsection 168(1) of the Excise Tax Act (ETA). ... For example, Cco may have reduced the consideration payable by the recipients and the recipients may be required to pay consideration to Bco for the supplies made during the half-month period. ...

[nominal consideration tainting of non-compete] Summary of Presentation Official Response Q. 16. ... [nominal consideration tainting of non-compete] In very general terms, the rules concerning restrictive covenants are divided into two categories, the first being where there is no consideration for the restrictive covenant, and the second being where there is consideration. ... Accordingly, it would be common in drafting a restrictive covenant to state that the consideration is the sum of $1 and other valuable consideration etc. ...

Recaptured input tax credits- timing considerations CRA Response Q.23. ... If it is thereby required to pay the GST/HST and the consideration to the CRA, how does it account for the GST/HST on the payment in remitting its net tax for the applicable reporting period? CRA Response The CRA will take into consideration the comments made by the members of the CBA during the meeting and further review the matter prior to issuing a response. ...

The above notwithstanding, the CRA does have a process in place that takes into consideration Appeals’ decisions to identify opportunities for improvements in processes. ... Taking into consideration the input of stakeholders, the CRA further pursued its analysis of the legislative and system requirements needed to implement the RTPP. ... The feedback you have provided relating to elections will be taken into consideration during that process. ...

Petitioning tax debtor into bankruptcy What are the CRA's considerations as to when it will petition a tax debtor into bankruptcy rather than enter into an arrangement for payment? ... This would make it doubtful whether the operator actually has managerial or operational control of the joint venture, subject to consideration of all relevant facts and agreements. ... How does the Salaison decision impact on the CRA's considerations. ...

However, where the value of the consideration (or the part) that has not been paid or become due at the substantial completion date is not ascertainable, subsection 168(6) provides that the payment of GST/HST on that consideration (or that part) is deferred until such time as the consideration (or part) becomes ascertainable. ... Generally, if this is the case, the consideration (or part) that is the consideration for the supply of the construction service is ascertainable and that GST/HST is payable on the substantial completion date. ... Tax would have become payable by the SLFI under subsection 168(1) of the ETA on the earlier of the day the consideration for the supply was paid and the day the consideration for the supply became due. ...

It states that tax under Division II in respect of a taxable supply is payable by the recipient on the earlier of the day the consideration for the supply is paid and the day the consideration for the supply becomes due. ... Pursuant to section 152 of the ETA, consideration is due on the earlier of the date an invoice is issued, or would have been issued but for delay, and the date that the recipient is required to pay the consideration. Given the above, consideration was due on the date of each of the advance quarterly payments, and tax was payable on that consideration. ...

Size and penalties The Transfer Pricing Review Committee (TPRC) takes the size of the taxpayer and the size of the transaction into account in determining whether to penalize, although these are only a factor in the consideration. ... Therefore, commercial rationality requires consideration of the reasonable expectations of the best possible outcome for the entity. ... Determining how risk should be treated in a transaction will require consideration of the delineation exercise mentioned earlier, combined with an understanding of the economically relevant characteristics and the industry at large. ...

c) How would the value of the consideration for the rebate be calculated? ... Under paragraph 254(2)(c), the “total consideration” is the sum of the consideration payable for the housing itself (that is, the purchase price of $250,000) and the consideration payable for any other taxable supply of an interest in the housing (that is, the assignment fee of $150,000). ... In your example, the total consideration used to calculate the rebate is $400,000. ...