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Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

Lease intervals – Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Examples- When the province in which the greatest proportion of the Canadian rights can be used cannot be determined Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a movie chain's five cinemas situated in Nova Scotia and New Brunswick. ... Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

This will be the taxpayer’s only opportunity to submit additional information for the TPRC’s consideration. ... Recharacterization referrals In situations involving the application of paragraphs 247(2)(b) and (d), the TPRC uses a three-stage approach: Initial consideration Consideration of a formal referral Final consideration 1. ... The taxpayer should be encouraged to bring forward facts for consideration during the review. 2. ...

This will be the taxpayer's only opportunity to submit additional information for the TPRC's consideration. ... Recharacterization referrals In situations involving the application of paragraphs 247(2)(b) and (d), the TPRC uses a three-stage approach: Initial consideration Consideration of a formal referral Final consideration 1. ... The taxpayer should be encouraged to bring forward facts for consideration during the review. 2. ...

Lease intervals– Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Therefore, the supply of the intangible personal property is made in Ontario and subject to HST at a rate of 13% Rule 3 If Rule 1 and 2 do not apply, the supply is made in a given province under the following conditions: Consideration of $300 or less If the value of the consideration for the supply of the IPP is $300 or less, the supply is made in a province if: the supply is made through a permanent establishment of the supplier located in the province in the presence of an individual who is the recipient, or through a vending machine situated in the province the IPP can be used in the province Address in Canada obtained If the preceding rule does not deem the supply to be made in a province, the supply may be deemed to be made in a participating province if the supplier obtains an address of the recipient in the province in the normal course of business and if the IPP can be used in the province. ... See examples- Rule 3- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...

As consideration for the supply of the asset management services is due after December 14, 2009, GST/HST applies to the supply. ... Tax is payable by InvestCo under Division IV on the consideration for the supply of the asset management services. ... The activities undertaken by the dealership in respect of leases of vehicles would be taxable activities and any consideration received by the dealership for arranging the lease would be considered to be consideration for a taxable supply. ...