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28 October 2013 Ruling 144133-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration stewardship fees paid under Ontario waste diversion program are regulatory charges, not fees Pursuant to the Waste Diversion Act, 2002 (Ontario) (“WDA”), Waste Diversion Ontario (“WDO”), a non-share corporation, is responsible for operating waste diversion and recycling programs for designated wastes in cooperation with an industry funding organization (“IFO”) (i.e., Ontario Tire Stewardship (“OTS”) for used tires, Stewardship Ontario (“SO”) for municipal hazardous waste and Ontario Electronic Stewardship (“OES”) for used electrical and electronic equipment) and designates stewards (e.g., a company which imports the product into Ontario or which is the registered owner or licensee of the brand for the product) which it requires to pay fees to cover the costs of the particular waste diversion program, including the costs of the IFO of operating the program (e.g., collection, transportation and processing of waste), and of the related WDO and Ministry costs. In connection with ruling that the fees paid to OTS, OES and SO were not consideration for a supply (so that they could not claim input tax credits for HST on purchases of property or services in respect of the stewardship programs), CRA stated: [T]here is nothing within the WDA that makes stewards responsible for the implementation or operation of waste diversion programs or for the waste generated as a result of their products. ...

30 November 1991 Round Table (4M0462), Q. 3.3- Issuing of Shares: Consideration Less than the F.M.V. ... B) each holding one share, issues a third common share for nominal consideration to Mrs. ...

Bulletin LTT 10-2000 "Transactions for Nominal Consideration" November 2000-- summary under Subsection 2(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 2(1) Testacy and Intestacy: When a conveyance of land is registered from the personal representative of a deceased person to a transferee who is receiving the property in satisfaction of all or part of his/her beneficial interest in the estate of a deceased person, it is not subject to tax under the Act. The consideration will be set out as "nil" in paragraph 4 of the LTT affidavit, and paragraph 7 must state that the conveyance satisfies these conditions.... ...

23 December 2002 Technical Interpretation RITS 38588-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration municipal taxes paid by tenant are additional rent A commercial lease provided that the Tenant was to pay to the Landlord the rent and all additional rent as set out in the Agreement and that that the Tenant must pay to the Landlord the full rent payable under the Agreement. ...

IT-405 "Inadequate Considerations and Dispositions"-- summary under Paragraph 69(1)(a) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(a) ...

GST59 GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges-- summary under Section 219 Summary Under Tax Topics- Excise Tax Act- Section 219 ...

IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances"-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) ...

IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances"-- summary under Subsection 80(5) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(5) ...

Guide for Providers of Financial Services under "Special Provisions"- "Election for Nil Consideration for Closely Related Corporations"-- summary under Qualifying Group Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Group General discussion. ...

GST25 "Closely Related Corporations and Canadian Partnerships- Election or Revocation of the Election to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration"-- summary under Subsection 156(4) Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(4) All or substantially all generally means 90% or more.... ...