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TCC

Invesco Canada Ltd. v. The Queen, 2014 TCC 375

It provides that tax shall be paid on the value of the consideration for a taxable supply. ... The issue arises in respect to a valuation of the consideration for those services. According to the wording of subsection 165(1), the consideration must be “for the supply”. ...
TCC

McLarty v. The Queen, docket 97-3628-IT-G

The total consideration given by the Individual Joint Venturers for the Venture Data was $6,373,335 satisfied by $956,002 in cash and $5,417,333 by way of promissory notes in favour of Compton (the "Promissory Notes"). This consideration was the same amount as the consideration given by Compton to Seitel in proportion to the percentage interest in the Western Data Base (ie. 30.35%) 10.            ... He admits the facts in paragraphs 9 and 11 of the Notice of Appeal, except he says that the consideration given was for an interest in the Income Stream, and that the consideration by way of promissory notes was contingent. [3]            Pursuant to an application under Rule 58, this Court ordered on December 27, 2000 that this motion proceed without the admission of evidence. ...
FCA

Madsen v. Canada, 2006 FCA 46

The document used in the transfer stated that the consideration paid was $1.00. ... " He could not accept it as consideration sufficient to prevent the application of section 160. [5]                We agree. ... It is the fair market value of the consideration at the time of the transfer which governs. [8]                The appeal will be dismissed with costs. ...
TCC

Lim v. The King, 2024 TCC 135

Lim”) for no consideration. At the time of the transfer of his half share of the family home, Mr. ... Lim with consideration in the amount of $530,000, in exchange for Mr. ... Did the Appellant provide consideration for the transfer of property? ...
FCA

Canada v. Canadevim Ltée, 2011 GSTC 62, 2011 FCA 128

LEGISLATIVE FRAMEWORK [14]            Under subsection 168(1) of the ETA, GST in respect of a taxable supply is payable on the earlier of the day the consideration for the supply is paid (inapplicable here) or the day the consideration for the supply “becomes due”. ...   [36] Indeed, since Parliament has seen fit to specify that, where there is a written agreement, the consideration becomes due only when the work is substantially completed, it seems to me that this is a good reference point for determining when the consideration becomes due in instances where the supplier has issued no invoice for the consideration. ... No such question is raised here, since there was an agreement on the work to be carried out and the consideration to be paid ...
TCC

Corporation des loisirs de Neufchâtel v. The Queen, [2008] GSTC 153, 2006 TCC 339

  [13]     Article 5 deals with the [translation] "Consideration". ... The Queen, [2002] G.S.T.C. 11, constitute consideration for the supply of a service to parents ...   [54]     Where there is a direct link between the subsidy and the price of the service, the subsidy must be regarded as the consideration, or part of the consideration, for the service, and it is taxable if the service is taxable ...
TCC

Dubois v. The Queen, 2003 TCC 16

Thus, the Appellant submits that the consideration that he gave at the time of the transfer of the Property is higher than the consideration set out in the contract of sale ... In my view, if the amount of the consideration set out in the written contract does not reflect the fair market value, at the time of the transfer, of the consideration given, the Act would be applied incorrectly if the consideration set out in the contract were used in order to make an assessment under section 160. ... In addition, it is my view that the fair market value, at the time of the transfer, of the consideration given, also includes anything that may have been given in consideration for the property up until the date of the transfer ...
TCC

Tendances et Concepts Inc. c. La Reine, 2011 TCC 141 (Informal Procedure)

That time cannot extend beyond the day on which the supplier applies a deposit as partial consideration. ... On the other hand, a deposit on account of consideration represents a partial payment of the consideration for a supply at the time of making the contract giving rise to the supply. ... Example of an Amount that Constitutes a Deposit on Account of Consideration   12. ...
TCC

Abdulnour v. The Queen, 2013 TCC 34 (Informal Procedure)

Although Exhibit A‑2 does not indicate the true consideration, the amount given as consideration was established by the testimonies of Milad Abdulnour and Abdul Massih Abdulnour ... Hence, the consideration is two thirds of the balance, that is, $48,205.33. ... In this context, it is difficult to establish an exact consideration, if any. ...
TCC

155579 Canada Inc. v. R., [1997] 1 CTC 2011, 97 DTC 691

That subsection does not use the word “consideration” as does subsection 160(1). Indeed, subsection 160(1) speaks of the fair market value... of the consideration given for the property”. ... I do not interpret the words “the product of’ as meaning “consideration given for’. ...

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