Search - consideration

The amount paid or credited in such circumstances would not be consideration for a supply. ... The “value of the consideration” is defined under subsection 153(1) as “(a) where the consideration or that part (of the consideration) is expressed in money, the amount of the money; and (b) where the consideration or that part is other than money, the fair market value of the consideration or that part at the time the supply was made.” ... The consideration received by the Owner from the Emphyteutic Lessee is the monetary Rent payments made by the Emphyteutic Lessee and non-monetary consideration, i.e., the Building. ...

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. ...

Therefore, when arriving at FMV, section 154 does not provide a legislative basis to discount the consideration of an exempt supply in an attempt to remove an amount imbedded in the consideration of that supply. For example, where the consideration of a taxable supply of a residential complex is used as a comparable in a valuation methodology, the GST/HST imposed on that supply, even where the supply was “GST/HST included”, is excluded from the consideration. ... In other words, the consideration for the supply of animal care services could be reduced before Service Provider 1 charges GST/HST. c. ...

To determine the primary purpose of the supply being made the CRA will take into consideration the previously mentioned criterion. ... In the normal course of business, a GST registrant will sell property and accept either currency or a receivable (promise to pay) as consideration. ... The proposed RITC threshold amount is determined with reference to “the total of all consideration for taxable supplies…”. ...

Rather, the $1.00 fee would apply, making the transaction exempt by virtue of the nominal consideration rule. ... CRA’s response was essentially that this would be taken “under consideration” regarding certain cases. ... Further, a determination of whether novation occurs in a particular case requires consideration of all relevant facts. ...

We confirm that the fees charged would be consideration for a taxable supply. ... In consideration for its efforts, YCo is compensated by management fees calculated on an annual basis. ... This deemed consideration occurs whether or not the partner charges a fee to the partnership. ...

Respecting the tests in s. 20(1)(c)(ii), it might be considered that the note was consideration for property acquired. ... Section 80 of the ITA and reverse earn-outs Q.4(a) No s. 143.4 grandfathering In a situation involving the purchase of shares of a target corporation ("Target") by a newly formed corporation ("Newco") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven), can the CRA confirm that a reduction in the cost of the shares of Target (through the application of subsection 143.4(2) of the ITA) prior to the subsequent merger of Target with Newco would allow the debt to qualify as an "excluded obligation" (as defined in subsection 80(1) of the ITA) and, consequently, the settlement of the debt following the merger should not result in a "forgiven amount" (as defined in subsection 80(1) of the ITA)? ... In particular, the amendment of Reg. 5907(6) effective 18 December 2009 to no longer preclude the use of Canadian currency, did not affect the general considerations discussed by him. ...

If there is a standard contractual recital of $1 (but not a dollar more) of consideration and other good and valuable consideration, as an administrative concession CRA will consider that this does not preclude the exceptions from exemption from s. 68 allocation treatment from being available. ... The CRA is now prepared to accept that where a contract relating to granting a restrictive covenant uses words such as “$1 and other good and valuable consideration” simply to ensure that the contract is legally binding, and means in effect that “no more than a $1 worth of consideration” is conveyed by a purchaser for the restrictive covenant, such consideration will not, in and of itself, constitute proceeds received or receivable by the particular party for granting the RC for purposes of paragraph 56.4(6)(e) and paragraph 56.4(7)(d). ... If more than nominal consideration of $1 is paid for a restrictive covenant under the wording “$1 and other good and valuable consideration”, the exceptions set out in subsections 56.4(6) and (7) would not apply because the respective conditions in paragraph 56.4(6)(e) and paragraph 56.4(7)(d) would not be met. ...

B Co makes a damage payment to A Co in respected of the destroyed railcar otherwise than as consideration for the lease of the railcar. ... Under subsection 168(6) where tax is payable on a day for the supply of tangible personal property or real property and the value of the consideration or a part of the consideration for the supply of tangible personal property or real property is not ascertainable on that day, the tax becomes payable on the day the value of that consideration becomes ascertainable. ... If so, how would the value of the consideration for the supply be determined for purposes of applying the GST? ...

The payment is an amount other than consideration for the supply under the agreement. ... Furthermore, subsection 152(2) provides that consideration under a lease is deemed to become due when Tenant B is required to pay “the consideration” – does this refer back to subsection 168(9)? ... Pursuant to subsection 168(9) of the Act, a “deposit” given in respect of a supply would not become consideration paid for the supply until Landlord A applies it as consideration for the supply. ...