Search - consideration

There is no evidence before me that the Appellant made supplies for no consideration or nominal consideration. As a result, any supplies that it made that were not taxable supplies made for consideration were exempt supplies made for consideration. [158]    Subparagraph 141.01(2) (b) (ii) does not apply to the fact situation before me. ... That we could find no evidence of-- of taxable supplies for consideration being made on any of this space. [80] In cross-examination, Mr. ...

Under the terms of the CSA, the Appellant is not required to pay consideration. ... In fact, the CSAs between the Appellant and the Frontender do not create any liabilities for the Appellant to pay consideration. [65]         While paragraph 123(1)(a) addresses the definition of recipient where an agreement for the supply exists and consideration is payable pursuant to that agreement, paragraph 123(1)(b) determines the identity of the recipient by addressing the test of “who bears the liability to pay the consideration”. ... The Latecomers received the benefit and services of already constructed infrastructure for payment of consideration. ...

In the opening portions of rule (g), provision is made for the allocation of so much of the consideration as can reasonably be regarded as being in part the consideration for the disposition of depreciable property and for the allocation otherwise of that part of the consideration which can be reasonably regarded as having been paid for “something else”. ... When this factual situation occurs, the rule then permits the allocation of that part of the consideration received in the total transaction to depreciable assets as “can reasonably be regarded as being in part the consideration for disposition of depreciable property of a taxpayer”. ... Only the deed conveying the land on which no buildings were then located, was delivered upon receipt of the consideration of $280,000. ...

For the years 1999, 2000, 2003 and 2004, the Respondent only recognized consideration of $100,000 ($25,000 annually). ... This amounts to a further $37,500 of consideration from her for the transfers by her husband. ...   [20]         In total I have found at least an additional $267,800 of consideration from Mrs. ...

  [18]     Counsel for the respondent submits that none of the above should be considered as consideration for the property transfers. ...   [25]     I accept that it is possible for consideration to flow between spouses for purposes of section 160 (see Raphael v. ...   [26]     In order for consideration to be taken into account, it must be given for the property transferred. ...

On August 22, 1989, he transferred the property to the Appellant showing a consideration of “$1.00 and other good and valuable consideration”. ... Zaruk of the Aldergrove property in consideration of $1.00. This transfer was not registered until July 4, 1990 when Mr. ... Zaruk, on both occasions, transferred property to the Appellant for no or inadequate consideration at a time when Mr. ...

Secondly, they say that if section 160 does apply to a capital dividend, they provided consideration for the dividends that exceeded the amount of the dividends.     ... That consideration consisted of the Appellants filing the election, the unpaid work they had done for 782 over the years, and their loan of the dividend back to 782 ...     [28]          The Appellants’ argument that they provided consideration for the dividend cannot succeed either. ...

This Appeal concerns one such vehicle, a Mercedes Benz, that the Minister of National Revenue (the “Minister”) maintains was supplied by the Car Club London for consideration of $56,500 in 2010. ... The Appellant argues there was no sale and therefore no supply. [8]              The Respondent’s starting point is section 168(1) of the Excise Tax Act (the “ Act ”) which reads: 168(1)  Tax under this Division 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. [9]              The Respondent maintains the $56,500 was consideration for the supply of “the Mercedes Benz” and tax is therefore payable in September 2010. ... Tax would only be payable if that amount is consideration for the supply. [15]         This is a unique situation where there is a longstanding relationship between the supplier and the recipient. ...

Where a supply is made, and the consideration therefor is paid, by means of a coin-operated device, the following rules apply for the purposes of this Part: (a) the recipient shall be deemed to have (i) received the supply, (ii) paid the consideration for the supply, and (iii) paid any tax payable in respect of the supply, on the day the consideration for the supply is inserted into the device; and   (b) the supplier shall be deemed to have (i) made the supply, (ii) received the consideration for the supply, and (iii) collected any tax payable in respect of the supply, on the day the consideration for the supply is removed from the device.   ... Instead, by way of presumptions, it merely explains when a supply is made and received, and the consideration therefor is paid and received ... But as stated previously, it is limited to devices that are designed to accept only a single coin of 25 cents or less as consideration for the supply. ...

Normally, under Section 83(3), the consideration received by the appellant for these shares should have been excluded from his income. ... On February 22 the appellant sold the mining claims that he had acquired under this arangement to Winston Mines Limited for a consideration consisting of 75,000 free shares and 675,000 escrowed shares of that company. ... Under Section 83(3), those who, in consequence of their having provided a prospector with financial assistance, acquired mining properties that they disposed of to a corporation in consideration for shares in the capital stock of the corporation, are given the privilege of excluding from their income the consideration that they receive for these shares. ...