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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. ...

Where the excess land does not qualify as part of the residential complex, the self-supply rules relating to a residential complex would not apply to that portion of the excess land and any part of the GST paid on the consideration for the supply of a residential building and land that relates to such excess land would not be eligible for the housing rebates. ... The allocation must be based on a method that is fair and reasonable (for example, the fair market value of each of the properties) and consideration must be given to any restrictions and/or severance laws or regulations, in effect on the date of acquisition, of any part of the property, including the portion that does not qualify as the residential complex. ... The allocation of the consideration payable for the residential complex (including the qualifying land) and the non-qualifying land should be determined on a fair and reasonable basis. ...

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. ...

Sustainable Development Action Plan for 2011-2014 Next page Previous page Theme: environmental sustainability Goal 1: Minimize the impact of our operations on the natural environment (land, air, and water) Objective 1.1: Reduce and manage solid waste Long-term outcome: Zero waste to landfill Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 1.1.1: By March 31, 2014, CRA will have the No Waste program in 100% of facilities Measure: Percentage of facilities with the No Waste program 1.1.1.1 Implement the No Waste program in additional facilities (Annual) No Waste program in additional facilities F&A (SD)/ SD Network/ F&A (RPSID) 1.1.1.2 Develop and promote a CRA Composting Implementation Guide (2013) Guide and promotion activities F&A (SD)/ SD Network/- 1.1.1.3 [Footnote 2]Develop and promote a CRA Green Office and Meeting Guide [Footnote 3] (Annual) Guide and promotion activities F&A (SD)/ SD Network/- Target 1.1.2: By March 31, 2014, CRA will have battery recycling programs in 100% of facilities Measure: Percentage of facilities with battery recycling programs; Quantity of batteries recycled 1.1.2.1 Implement battery recycling programs in additional facilities (Annual) Battery recycling programs in additional facilities F&A (SD)/ SD Network/ F&A (RPSID) Target 1.1.3: By March 31, 2014, CRA will reuse or recycle all surplus electronic and electrical equipment (EEE) in an environmentally sound and secure manner Measure: Percentage of facilities with implemented EEE disposal plans 1.1.3.1 Establish a national implementation plan for the disposal of all surplus EEE (2012) National EEE disposal implementation plan F&A (AD)/ F&A (SD)/ ITB 1.1.3.2 Implement surplus EEE disposal programs in facilities (Annual) Facilities with EEE disposal programs F&A (AD)/ ITB, SD Network/- 1.1.3.3 Establish a methodology to track and report on surplus EEE disposal (2013) EEE disposal report F&A (AD)/ ITB/- Target 1.1.4: By March 31, 2013, CRA will achieve an 8:1 average ratio of employees to printing units where building occupancy levels, security considerations, and space configuration allow Measure: Employees to printing units ratio 1.1.4.1 Develop and implement a national printing device consolidation initiative to reduce the number of printing units (2012) Printing device consolidation initiative implemented F&A (AD)/ ITB, F&A (SD)/ SD Network 1.1.4.2 Develop/modify policy instruments to support the national printing device consolidation initiative (Annual) Developed/modified policy instruments F&A (AD)/ ITB/ F&A (SD) 1.1.4.3 Develop a national inventory of printing units (Annual) Inventory of printing units F&A (AD)/ ITB/ F&A (SD) Objective 1.2: Increase green procurement Long-term outcome: 100% green procurement Targets and measure Activity Output Accountability (OPI/OCI/Partner) Target 1.2.1: By March 31, 2014, 10% of CRA spending on products and services will be green procurement Measure: Percentage of annual green procurement spending on products and services 1.2.1.1 Include SD clauses and environmental specifications in all new contractual arrangements valued over $1M (Annual) Contractual arrangements with SD clauses and environmental specifications F&A (AD)/ F&A (SD)/- 1.2.1.2 Include green procurement criteria in all new publication contractual arrangements (Annual) Green publications PAB (EPMD)/ F&A (AD)/ F&A (SD) 1.2.1.3 Ensure all procurement officers with procurement authority have received green procurement training (Annual) Green procurement training report F&A (AD)/ F&A (SD)/- 1.2.1.4 Include environmental measures in the performance agreements or expectations of all managers and functional heads of procurement and materiel management (Annual) Performance agreements with environmental measures F&A (AD)/ F&A (SD)/- 1.2.1.5 Ensure 75% of procurement management processes and controls include environmental considerations based on PWGSC Guideline [Footnote 4] (2014) Procurement processes and controls with environmental considerations F&A (AD)/ F&A (SD)/- Objective 1.3: Reduce paper consumption Long-term outcome: Paperless options for all CRA internal and external programs Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 1.3.1: By March 31, 2014, CRA will reduce office paper use per full-time equivalent (FTE) by 28% [Footnote 5] from baseline year 2005-2006 Measure: Percentage reduction of office paper purchased per FTE from baseline year 1.3.1.1 Coordinate a national paper reduction campaign (Annual) Paper reduction campaign F&A (SD)/ SD Network/- 1.3.1.2 Implement paper reduction initiatives from the 2008 Agency Paper Use Scan [Footnote 6], as feasible (2013) Paper reduction initiatives F&A (SD)/ Branches, Directorates /- 1.3.1.3 Revise the procedures for processing Access to Information Act and Privacy Act (ATIP) requests to reduce paper use requirements and realize efficiencies (2014) Revised ATIP procedures PAB (ATIPD)/ F&A (SD)/- 1.3.1.4 Convert internal forms to Intra-form [Footnote 7] format (Annual) Intra-forms PAB (PSD)/ F&A (SD), SD Network/- Target 1.3.2: By March 31, 2014, CRA will reduce the paper used for external publications by 10% from baseline year 2008-2009 Measure: Percentage reduction of paper used for external publications 1.3.2.1 Measure paper used for external publications (Annual) External publications paper use report PAB (EPMD)/ F&A (SD)/- 1.3.2.2 Include paper reduction initiatives in the Agency Publication Plan (APP) process (Annual) APP paper reduction initiative report PAB (EPMD)/ F&A (SD)/ ABSB (IRD, BRD), HRB (WRCD) 1.3.2.3 Introduce/update SD criteria in the CRA Publishing Policy and establish Agency external paper [Footnote 8] reduction directive and guidelines (2014) Updated policy, directive and guidelines PAB (EPMD)/ F&A (SD)/- Objective 1.4: Reduce GHG emissions Long-term outcome: Carbon neutral operations Target and measure Activity Outputs Accountability (OPI/OCI/Partner) Target 1.4.1: By March 31, 2014, CRA will reduce greenhouse gas (GHG) emissions from fleet vehicles by 5% from baseline year 2005-2006 [Footnote 9] Measure: Percentage reduction of GHG emissions from fleet 1.4.1.1 Ensure all vehicles purchased are right-sized and most fuel efficient in class based on operational requirements [Footnote 10] (Annual) Right-sized and most fuel efficient in class vehicles purchased F&A (AD)/F&A (SD)/- 1.4.1.2 Review and improve the measures to rationalize, rejuvenate and right-size CRA fleet within the fleet management policy instruments and processes (2013) Updated measures F&A (AD)/ F&A (SD)/ Regional fleet managers 1.4.1.3 Promote fleet management training initiatives to fleet managers and drivers (2012) Promotion activities F&A (AD)/ Regional fleet managers, F&A (SD)/- Target 1.4.2: By March 31, 2014, CRA will achieve a 5% shift towards sustainable travel options for business and commuter travel from baseline year 2007 Measure: Percentage shift in the use of sustainable travel options 1.4.2.1 Introduce/update SD criteria in policy instruments and processes related to business and commuter travel during regular review cycles (Annual) Updated policy instruments and processes F&A (FAD, RPSID, AD), HRB/ F&A (SD)/- 1.4.2.2 Promote sustainable business travel options (Annual) Promotion activities F&A (FAD, AD)/ F&A (SD), SD Network/- 1.4.2.3 Inform employees of sustainable commuting options (Annual) Commuting information F&A (SD)/ SD Network/- 1.4.2.4 Introduce/update SD criteria in facility site selection and leasing processes (2014) Updated site selection and lease processes F&A (RPSID)/ F&A (SD)/- 1.4.2.5 Prepare recommendations report for realizing efficiencies from alternative work arrangements (2013) Recommendations report F&A (SD)/ F&A (RPSID)/- 1.4.2.6 Reduce the CRA real property footprint through alternative work arrangements (2014) Reduced accommodation requirements SD Network/ F&A (RPSID)/- Target 1.4.3: By March 31, 2014, CRA will reduce energy use from office equipment by 20% in selected facilities from baseline year 2009-2010 and reduce energy use in data centres Measure: Percentage reduction in energy use in selected CRA facilities and in data centres 1.4.3.1 Promote energy conservation best practices (Annual) Promotion activities F&A (SD)/ SD Network/- 1.4.3.2 Measure energy use from office equipment in selected facilities (2014) Energy use report F&A (SD, RPSID)/-/- 1.4.3.3 Implement energy conservation initiatives in CRA data centres (2014) Energy conservation initiatives ITB/ F&A (SD, RPSID)/- Objective 1.5: Comply with federal regulations Long-term outcome: Zero pollution Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 1.5.1: By March 31, 2014 CRA will improve the management of halocarbon containing equipment [Footnote 11] and petroleum storage tank systems to minimize environmental impacts Measure: Percentage of CRA facilities with up-to-date halocarbon and petroleum storage tank system inventories; Number and amount of halocarbon releases 1.5.1.1 Maintain an up-to-date CRA national halocarbon inventory (Annual) Completed national halocarbon inventory F&A (SD)/ SD Network/- 1.5.1.2 Develop halocarbon product replacement plans to replace/eliminate outdated systems (2014) Product replacement plans F&A (SD)/ SD Network/- 1.5.1.3 Maintain an up-to-date CRA petroleum storage tank system [Footnote 12] inventory (Annual) Petroleum storage tank system inventory F&A (SD)/ ITB/- 1.5.1.4 Conduct reviews to ensure that the CRA petroleum storage tank systems comply with Federal regulations (2013) Federal regulations compliance F&A (SD)/ ITB/- Footnotes Footnotes Footnote_ftn2 This commitment contributes to the Federal Sustainable Development Strategy and has mandatory annual accountability requirements in CRA Report on Plans and Priorities and Departmental Performance Report. ...

In the case of beneficiaries of a personal trust, there is no reduction of the adjusted cost bases of their capital interests unless they were acquired for consideration. A personal trust, defined in subsection 248(1), is either a testamentary trust or an inter vivos trust in which no beneficial interest was acquired for consideration payable to the trust or to a person who has made a contribution to the trust. ... For the purposes of the definition of a personal trust, love and affection will not be regarded as consideration. ...

Paragraph 1 of the bulletin is revised to take into consideration the repeal of section 88.1 and the enactment of subsections 128.1(4) and 250(5.1) under S.C. 1994, c.21 (formerly Bill C-27) generally applicable after 1992. ... Paragraph 5(viii.1) is added to the bulletin to take into consideration the enactment of paragraph 219(1)(f.1) under S.C. 1994, c.7 applicable to interest and penalties paid in the 1988 and subsequent taxation years. ... Paragraph 16 of the bulletin is revised to take into consideration the amendment made to subsection 808(3) of the Regulations by P.C. 1993-1548, SOR 93-395 applicable to taxation years ending after August 11, 1993. ...

She offered the following questions for consideration: What is the most important thing that was discussed (or not discussed) yesterday? ... There was a substantive discussion about the working group’s current priorities and ultimately, the ACCS agreed this working group would narrow its focus to the following two key issues: Review of the charities registration process, including a consideration for consultations with the sector Review of ACCS Reports #1, 2, and 3 to seek greater clarity on the status of these items from the CRA Transparency and data related to other qualified donees and non-profit organizations working group (TDWG) Exercise Kevin McCort provided an update on the group’s work to date on the following topics: other qualified donees; taxonomy of language around charities and non-profit organizations; T3010 form, Registered Charity Information Return, and T1044; and, Non-Profit Organization Information Return. Kevin raised the following questions for consideration: How can an effort for greater data collection and accuracy through the required T3010 and T1044 forms be significantly advanced when long term structural issues prevent timely, critical improvements? ...

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. ...

Observations In reviewing the receipt and handling of the ITQ responses, no fairness considerations were identified by the Fairness Monitor. ... Concurrent to the conduct of the one-on-one meetings, CRA continued to refine its requirements in updates to the preliminary Statement of Work, in consideration of the findings from these sessions. ...

Therefore, where the consideration for a supply was excluded from the calculation of financial revenue described above in paragraphs 16 to 26, it would still be included in the calculation of total revenue for purposes of the de minimis threshold test in paragraph 149(1)(b). ... However, when calculating total revenue under clause 149(1)(b)(i)(B), it is the CRA's position that the actual consideration paid or payable for supplies between closely related persons, and not the deemed amount of zero, should be included. For further information on the election for nil consideration, refer to GST/HST Memorandum 14.5, Election for Nil Consideration. 30. ...