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Administrative Policy summary

October 1989 Revenue Canada Round Table - Q.4 (Jan. 90 Access Letter, ¶1075) -- summary under Subsection 245(4)

However, the previously observed practice of RC was to show tolerance where the transaction was motivated by economic or commercial considerations. ...
Administrative Policy summary

Excise and GST/HST News No. 87 Winter 2013 -- summary under Section 2

GST/HST will generally apply to the consideration paid by the medical laboratory for the services of the independent contractors. ...
Administrative Policy summary

23 December 2002 Technical Interpretation RITS 38588 -- summary under Subsection 165(1)

23 December 2002 Technical Interpretation RITS 38588-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) "Where a separate amount is paid by a lessee on account of property taxes, this amount is part of the consideration for the rental of the property, even if the lessee pays the amount directly to the municipality... ...
Administrative Policy summary

30 November 1991 Round Table (4M0462), Q. 6.1 - Contribution of Knowledge vs. Financial Contribution (C.T.O. September 1994) -- summary under Subsection 103(1)

September 1994)-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) A payment made, or a credit made to a partner's 'capital' account, in consideration of its commitment to perform work for the partnership will be considered to be business income for the partner. ...
Administrative Policy summary

IT-291R3 "Transfer of Property to a Corporation under Subsection 85(1)" -- summary under Paragraph 85(1)(b)

IT-291R3 "Transfer of Property to a Corporation under Subsection 85(1)"-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) allocation of assumed debt amongst transferred properties 17 … Paragraph 85(1)(b), however, will not apply where the fair market value of the non-share consideration given (including the assumption of debt by the transferee) is allocated among several properties transferred and retained by the transferee and the amount allocated to each asset is not greater than the agreed amount in respect of each asset. ...
Administrative Policy summary

92 C.R. - Q.44 -- summary under Subsection 15(2.6)

.- Q.44-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) Although there is no statutory relief to a non-resident where a particular loan, that previously was subject to s. 15(2) and s. 214(3)(a), is repaid, RC will give consideration to a request that the amount of tax should not be subject to withholding tax a second time if, and when, a dividend is paid to the non-resident. ...
Administrative Policy summary

92 C.R. - Q.44 -- summary under Paragraph 20(1)(j)

.- Q.44-- summary under Paragraph 20(1)(j) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(j) Although there is no statutory relief to a non-resident where a particular loan, that previously was subject to s. 15(2) and s. 214(3)(a), is repaid, RC will give consideration to a request that the amount of tax should not be subject to withholding tax a second time if, and when, a dividend is paid to the non-resident. ...
Administrative Policy summary

B-067 "Goods and Services Tax Treatment of Grants and Subsidies," 24 August 1992 -- summary under Supply

B-067 "Goods and Services Tax Treatment of Grants and Subsidies," 24 August 1992-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply In general, transfer payments made for a public purpose or for charitable purposes will not be consideration for a supply under the ETA unless there is a "direct link" between the payment and a provision of goods and services made to the grantor of the funding or a specified third party. ...
Administrative Policy summary

81 C.R. - Q.54 -- summary under Disposition

.- Q.54-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where an investor grants to a person or persons the right to distribute film in markets representing most or all of the exploitable value of the film for a guaranteed minimum consideration equal to its fair market value, there is a disposition. ...
Administrative Policy summary

Interpretation Revenu Québec TVQ. 16-30/R1 "Nominee Agreements" 9 December 2011 -- summary under Subsection 221(2)

A nominee who fails to disclose, to the supplier of an immovable, the fact that the nominee is a mandatary is acting in the nominee's own name and becomes personally bound to the supplier to pay the consideration for the supply (article 2157 C.C.Q.). ...

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