Search - consideration

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. ...

Assume further that the consideration for the transfer of the mortgages/receivables, if supplied separately by Company A, would be greater than 50% of the total consideration for all services or property supplied to the SPV by Company A if that service or property had been supplied separately. ... Where the consideration for the supply is expressed in money, the value of consideration is generally deemed to be the amount of the money under paragraph 153(1)(a) of the ETA. ... Where consideration for the supply is payable under an agreement for the supply, the recipient of the supply is the person who is liable under the agreement to pay that consideration. ...

Therefore, this is not a single consideration and precludes the use of section 139. ... As a result of the election, the supplies made between the corporations are deemed to be made for nil consideration. ... If the horse wins a race, pursuant to subsection 188(2) of the ETA, the consideration is deemed not to be consideration for a taxable supply. ...

A transfers his shares of the capital stock of Opco 1 to Opco 2 in consideration for a note Paragraph 84.1(1)(b) applies and a dividend is deemed to have been paid by Opco 2 to Mr. ... Under s. 212.1(6)(b)(ii), each non-resident beneficiary will be deemed to have received consideration other than the shares of the purchaser corporation, and that consideration received will, again, be equal to the proportion of their interest in the trust. ... Z taking into consideration the application of the deeming rule in subparagraph 120.4(1.1)(b)(ii)? ...

Would this be consideration other than shares of Parent for purposes of subsection 87(4)? ... Scenario 2 Prud'Homme: In this situation, of course, the reduction in value of the shares held by the Target shareholders is made as consideration for the settlement of the indemnity claim. ... The present scenario deals with an exchange – there is a disposition of the shares of US Pubco and, as consideration, shares of Spinco are received. ...

By “reasonable and realistic,” the CRA means that it should be reflective of the actual consideration paid for the copyright described under the exception in s. 212(1)(d)(vi). ... Whether a particular apportionment of the consideration paid is reflective of the actual payments described in the exemption under s. 212(1)(d)(vi) depends on the legal nature of what is being provided under a mixed contract. The relationship between the parties and the facts of the particular situation, including the commercial reality of the parties and the consideration paid, would be considered. ...

The first stage is informal initial consideration. The second stage is usually after the audit work is well underway, mostly completed, and we are about to propose recharacterization – it comes to the TPRC for formal approval. ... Jennings: Our administrative approach was outlined on our website, including guidance on corporate residency, permanent establishments, and other similar considerations. ... There are also some files that are under consideration for referral to the Third Party Penalty Committee. ...

In this kind of situation, the insurer of the individual will generally pay as an indemnity for damages the consideration payable to the contractor plus the GST payable with respect to that consideration. ... GST/HST is applicable to the consideration for a taxable supply made in Canada. ... Rather, the goods are reconveyed by the purchaser to the retailer for consideration. ...

We will take your suggestions into consideration for future system enhancements. ... All facts surrounding the situation must be taken into consideration as a whole and not in isolation. ... Has CRA given any consideration to allowing this type of access? CRA Response Thank you for the suggestion. ...

Part #2 Under s. 168, the GST collectible under a lease depends on the time at which the consideration under the lease is paid or becomes payable. ... Under subsection 168(1), tax 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. Under subsection 152(2), where property is supplied by way of lease, licence or similar arrangement under an agreement in writing, the consideration, or any part thereof, for the supply shall be deemed to become due on the day the recipient is required to pay the consideration or part to the supplier pursuant to the agreement. ...