Search - consideration

However, shares of the parent issued as consideration for the shares of the subsidiary are expressly excluded from the rule. ... On the other hand, the provision would not ordinarily apply to conventional common or preferred shares or debt issued by the parent as consideration for the acquisition of the shares of the subsidiary. ...

As there is no indication in the agreement of purchase and sale with the builder that FinanceCo is liable to pay the consideration for the supply by the builder of the condo, CRA rules that Purchaser is liable for the GST on the value of the consideration for that supply, and that FinanceCo is not the recipient of that supply. ...

Where the registrant who acquires the continuous transmission commodity from the first buyer is not acquiring the commodity for consumption, use, or supply exclusively in the course of commercial activities of the registrant, the supply is an imported taxable supply and the registrant is liable for tax under sections 218 and 218.1, calculated on the value of the consideration for the supply of the commodity. ... In addition, every recipient of an imported taxable supply of continuous transmission commodity, that is delivered or made available to the recipient in a particular participating province where the recipient is either a resident or is a registrant, must self-assess an amount of the provincial part of the HST under subparagraph 218.1(1)(b)(ii), equal to the tax rate for the particular participating province multiplied by the value of the consideration for the supply. ...

13 March 1997 Interpretation 11735-1, 11720-1-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) damages from car renter not additional consideration for rental A rented car is damaged, the car rental company pays a body shop for repairs plus GST, claims an ITC for such GST and then obtains recovery from the customer for its repaid cost excluding the GST. ... It would therefore not be correct to categorize any additional payment that may be required, as consideration for the taxable supply of the rental of the car because the additional payment is not always required. ...

7 December 2016 Ruling 158637-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply contract cancellation fee not consideration for a supply A registered charity, which is also registered for GST/HST purposes, charges employers or sponsors fees for providing training to apprentices, and also charges a cancellation fee if the apprentice withdraws from training during a specified time period. After finding that the training charge was consideration for a single supply that was exempted under Sched. ...

[U]nder subsection 141.01(2), the PSB is deemed to have acquired property or a service for consumption or use in commercial activities only to the extent that the property or service is acquired for the purpose of making taxable supplies for consideration in the course of an endeavour of the PSB. To the extent that the property or service is acquired for the purpose of making supplies in the course of an endeavour that are not taxable supplies made for consideration or for a purpose other than making supplies, the PSB is deemed to have acquired the property or service for consumption or use otherwise than in commercial activities. ...

Consequently, a refund or credit to the Project Co, as provided for under the Guarantee would be regarded as a subsequent reduction in consideration pursuant to subsection 232(2). … Note that the legislation uses the word “may”. As such, it is at the discretion of the Joint Venture (the particular person) whether to refund the GST on the reduction in consideration. ...

26 April 2001 Ruling 35383-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 2 reimbursement to manager of nursing home of payroll not consideration for a taxable supply Company A (a registered charity) and Company B form a joint venture to establish and operate an interim-care nursing home, with each supplying institutional health care services. ... Ruling The allocation to the payroll expenses to the joint venture participants are not subject to GST as the amounts are not consideration for a taxable supply. ...

CRA responded: If a retired partner makes a supply to the partnership such as, for example, a consulting service, the payment may be consideration for the supply and the GST/HST may be applicable to the supply. ... To the extent that payments made by a partnership to a retired partner are in respect of an interest in the partnership, or any right in respect of such an interest, the payment would be consideration for an exempt supply of a financial service …. ...

Bank C uses the appraisal service directly and exclusively to provide an exempt financial service of issuing a mortgage loan to a homebuyer in Canada (that is, the service is in no way used to provide a taxable supply for consideration). The supply of the appraisal service is an exclusive input of Bank C because it is not an excluded input and it is acquired by Bank C for consumption or use directly and exclusively for purposes other than making taxable supplies for consideration (that is, for making exempt supplies of financial services). ...