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Scraped CRA Website

Tax Status of Flying Time Pursuant to Section 8 of Part III of Schedule V to the ETA

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. ...
Current CRA website

Application of the HST to Imports

In the case of an imported taxable supply of tangible personal property (including drop shipments) the tax is to be assessed based on the full value of the consideration that is paid or becomes due. For any other property or service, the tax is to be assessed on the percentage of the total consideration paid for the supply that the consumption, use or supply by the recipient in the participating province, is of the total consumption, use or supply of the intangible personal property or service. ... Payment of tax (s 218.2, s 219) The provincial component of the HST relating to imported taxable supplies is payable on an amount of consideration for a supply each time it becomes due or is paid without having become due. ...
Current CRA website

Trusts

Any amount to which the trustee is entitled for acting as a trustee of the trust that is included in computing the trustee's income under the ITA, or where the trustee is an individual, the individual's business income, is deemed to be consideration for the supply of that service. ... The consideration for the supply is deemed to be equal to the amount determined under the ITA to be the proceeds of disposition of the property. ... The consideration for the deemed supply of the property is deemed to be equal to the amount determined under the ITA to be the proceeds of disposition of the property. ...
Current CRA website

Installments (GST 500-2-2)

In these calculations, consideration for most taxable supplies (including zero-rated supplies) that became due or was paid without having become due to the person during a specified period is aggregated with a similar total for all associated persons. 3. ... The instalment base of the registrant for reporting periods that begin before 1992 is the lesser of (a) 75 per cent of the amount as determined under paragraph 237(2)(a) of the Act, and (b) the amount determined by the formula A x B x 365/C where A is the prescribed percentage, B is the total consideration received by or due to the registrant for supplies of property (other than supplies by way of sale of capital property of the registrant) or services by the registrant in the fiscal year of the registrant that immediately preceded that reporting period, and C is the number of days in the fiscal year of the registrant that immediately preceded that reporting period. 17. ... For example, assume that in the fiscal year immediately preceding the "transitional" reporting period, total consideration for supplies as defined above was $300,000, and the applicable prescribed percentage was five per cent. ...
Archived CRA website

ARCHIVED - Excise and GST/HST News - No. 92

The core charge forms part of the consideration payable for the new part. ... Where the non-registrant supplies the used part to the vendor at the time the new automotive part is purchased, the GST/HST trade-in rules apply and the GST/HST is calculated on the difference between the consideration payable, including the core charge, for the new part being sold and the amount credited for the trade-in. ... The vendor is required to collect GST/HST on the total consideration payable for the new part, including the core charge. ...
Current CRA website

Chapter History S1-F3-C3, Support Payments

. ¶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 to 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. ...
Current CRA website

General anti-avoidance rule (GAAR)

Transactions – Scenario 1 Individual holds high ACB Class B shares on which the capital gains exemption was previously crystallized Subco transfers Property A to Holdco in consideration for Class B shares of Holdco As a result, the PUC of the Class B shares is increased across all Class B shares Before: Image description The before image shows the situation before entering the series of transactions. ... After: Image description The after image shows the result of the transaction in which Subco transferred Property A to Holdco in consideration for Class B shares of Holdco. ... Transactions – Scenario 2 Canco redeems the preferred shares held by the individual, triggering a deemed dividend of $849,999 and an equivalent capital loss which is added to the ACB of the common shares under subsection 40(3.6) Individual transfers their common shares to Holdco in consideration of preferred shares with an ACB and redemption value equivalent to the $850,000 and nominal value common shares Holdco redeems the preferred shares without any tax consequences Before: Image description The before image depicts the following: The individual holds common shares and preferred shares of Canco. ...
Current CRA website

Platform-based short-term accommodation

An accommodation platform operator in respect of a supply of short-term accommodation made through an accommodation platform, generally means a person (other than the supplier or an excluded operator in respect of the supply) that controls or sets the essential elements of the transaction between the supplier and the recipient; and if the above does not apply to any person, then it is a person who is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier. In relation to a supply of property, an excluded operator is a person who: does not set, directly or indirectly, any of the terms and conditions under which the supply is made, is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply, and is not involved, directly or indirectly, in the ordering or delivery of the property; or solely provides for the listing or advertising of the property or service or for the redirecting or transferring to a digital platform on which the property is offered; or is solely a payment processor. ...
Current CRA website

Supply of qualifying goods in Canada

A distribution platform operator in respect of the supply of qualifying goods made through a specified distribution platform is a person other than the supplier or an excluded operator who: controls or sets the essential elements of the transaction between the supplier and the recipient, or if that circumstance does not apply to any person, is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier. In relation to the supply of qualifying goods, an excluded operator is a person who: does not set, directly or indirectly, any of the terms and conditions under which the supply is made, is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply, and is not involved, directly or indirectly, in the ordering or delivery of the property; or solely provides for the listing or advertising of the property or for the redirecting or transferring to a digital platform on which the property is offered; or is solely a payment processor. ...
Current CRA website

Pacific Association of Tax Administrators (PATA) Transfer Pricing Documentation Package

The extent of the use of CCA property by associated enterprises which are not CCA participants, including the amounts of consideration paid or payable by these non-participants for use of the CCA property. ... For the taxpayer and the comparable, identify the factors taken into account by the taxpayer to evaluate comparability, including the characteristics of the property or service transferred, the functions performed (and the significance of those functions in terms of their frequency, nature and value to the respective parties), the assets employed (taking into consideration their age, market value, location, etc.), the risks assumed (including risks such as market risk, financial risk, and credit risk), the terms and conditions of the contract, the business strategies pursued, the economic circumstances (for example, the geographic location, market size, competitive environment, availability of substitute goods and services, levels of supply and demand, nature and extent of government regulations, and costs of production, etc.), and any other special circumstances. Criteria used in the selection of comparables including database screens and economic considerations. ...

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