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. ¶3.35 (formerly ¶18 of IT-530R) has been modified to emphasize the requirement for a court order or written agreement and also that the amount deductible under paragraph 60(b) is the total of all amounts determined by the formula in paragraph 60(b) after giving consideration to support amounts paid to a particular person. ¶3.40 (formerly ¶10 of IT-530R) has been modified to expand the discussion of adjusting support amounts where the court order or written agreement gives consideration to bonuses and incentive payments. ¶3.42 has been added to address circumstances similar to former ¶11 where a support amount is offset by an equalization amount owed by the recipient to the payer. ¶3.44 (formerly contained in ¶22 of IT-530R) has been has been changed to note the CRA’s general acceptance of the Tax Court of Canada decision in Craig James v HMTQ, 2013 TCC 164, 2013 DTC 1135 for a lump-sum payment for retroactive periodic maintenance paid pursuant to a court order. ¶3.45 (formerly contained in ¶22 of IT-530R) has been expanded to clarify that where a lump-sum amount meets the requirements of a support amount, it is deductible by the payer and included in the income of the recipient. ... The paragraph has also been modified to clarify that the payer may be entitled to personal tax credits after the death of the recipient. ¶3.68 has been added to discuss the treatment of payments directly from a pension plan to the recipient and includes a reference to paragraph 11 of Interpretation Bulletin IT-499R, Superannuation or Pension Benefits. ¶3.73 has been added to refer readers to Interpretation Bulletin IT-513, Personal Tax Credits. ¶3.74 (formerly ¶35 of IT-530R) has been modified to note that the restriction in subsection 118(5) is applied in respect of a particular person as well as giving consideration to amounts paid to third parties. ¶3.75 – 3.76 have been added to include discussion of the exception in subsection 118(5.1) for claiming a personal tax credit in respect of a person where more than one individual is required to make a child support payment in respect of that person. ...

A discounter (within the meaning of the Tax Rebate Discounting Act) who pays an amount to a person to acquire from the person a right to a refund of tax (within the meaning of the Tax Rebate Discounting Act), notwithstanding section 139 Footnote 1, is deemed to have made two supplies: (a) a taxable supply of a service for consideration equal to the lesser of: (i) 2/3 × (refund- amount paid to the person by the discounter); and (ii) $30; and (b) a separate exempt supply of a financial service. ... As a result, the consideration for the taxable supply equals 2/3 of the difference between the actual tax refund and the amount paid by the discounter to the client, to a maximum of $30. The remainder of the fee (or discount) charged by the discounter to the client is treated as consideration for the financial service. ...

An "improvement" in respect of capital property is defined in section 123(1) of the Act as any property or service to the extent that the consideration for the property or service would be included in determining the adjusted cost base of the capital property for income tax purposes. Where the capital property in question is a residential complex, the improvement must relate to a property or service the consideration for which is included in the adjusted cost base of the residential complex. ... Other property and services that are supplied in respect of the land, interest, building or appurtenance that form part of the single unit residential complex may also be eligible for rebate as an improvement provided the consideration paid or payable for such property or service would be included in determining the adjusted cost base of the complex for income tax purposes. ...

In order to take advantage of the capital gains deduction under subsection 110.6(2.1) of the Act before the shares cease to be qualified small business corporation shares, the individual sells the shares to a related corporation in consideration for shares and elects an amount under subsection 85(1) of the Act that will permit the individual to take the maximum capital gains deduction. ... Interpretation Section 84.1 of the Act describes the circumstances in which consideration received by a taxpayer on a sale of shares to a corporation should be accounted for as a dividend. ... Interpretation The shares of the subsidiaries issued in consideration for the property comprising businesses A and B are deemed by section 54.2 of the Act to be capital property of Canco. ...

Under subparagraph 40(2)(g)(ii), a taxpayer's capital loss on the disposition of a debt or other right to receive an amount is nil unless (a) the debt or right was acquired by the taxpayer for the purpose of gaining or producing income (other than exempt income) from a business or property, or (b) the debt or right was acquired by the taxpayer as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm's length. ... (Where the debt in question is a loan bearing less than a reasonable rate of interest, refer to IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances".) 3. ... The debt was not acquired by the taxpayer for the purpose of gaining or producing income or as consideration for the disposition of capital property to an arm's length person, so that subparagraph 40(2)(g)(ii) prevents a claim in respect of a $1,000 capital loss. ...

If a share is acquired for consideration other than cash or warrants, the cost amount of the share is the fair market value of the consideration surrendered for the share itself, net of brokerage or similar charges. 14. ... For 1987 and subsequent taxation years, a claimant will have to take into consideration any carry-forward of unused credits and any recaptures of credits previously received. 20. ...

GST/HST Policy Statement P-164 Date of Issue February 15, 1994 Subject Rent-to-own agreements Legislative Reference(s) The following provisions of the Excise Tax Act may apply: 123(1) Definition of "sale"; 133 Agreement as supply; 152(2) Consideration under leases; 168(5) Sale of real property; 168(6) Combined supply; 191(1) & (3) Self-supply of residential real property; 191(2) Self-supply on termination of purchase and sale agreement; 254 GST New Housing Rebate; 336 Transitional provisions National Coding System File Number(s) 11870-5 Effective Date January 1, 1991 Text This policy statement will discuss the transfer of possession of a newly constructed or substantially renovated residential complex from a builder to a recipient under a lease, licence or similar arrangement before transfer of ownership of the complex to the recipient. ... If the sale is taxable, the recipient will generally be required to pay GST on the value of the consideration for the sale at the earlier of the transfer of possession and the transfer of ownership of the property. ... GST will be payable on the value of consideration at Jan. 1, 1993, however, the GST New Housing Rebate will not be available before the transfer of title. ...

The aeroplane, 35 hours of dual flight time and 30 hours of solo flight time are provided by the vocational school for a single consideration. ... Scenario No.2: The vocational school provides the 35 hours of dual flight time, 30 hours of solo flight time, 90 hours of build-up time, ground school instruction and the use of an aeroplane for the purposes of completing the flight time, for a single consideration. ... Scenario No. 3: The vocational school provides the solo flight time, dual flight time and ground school instruction for a single consideration. ...

An "improvement" in respect of capital property is defined in section 123(1) of the Act as any property or service to the extent that the consideration for the property or service would be included in determining the adjusted cost base of the capital property for income tax purposes. Where the capital property in question is a residential complex, the improvement must relate to a property or service the consideration for which is included in the adjusted cost base of the residential complex. ... Other property and services that are supplied in respect of the land, interest, building or appurtenance that form part of the single unit residential complex may also be eligible for rebate as an improvement provided the consideration paid or payable for such property or service would be included in determining the adjusted cost base of the complex for income tax purposes. ...

Pursuant to paragraph 183(1)(b), that supply is deemed to have been made for no consideration. ...