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National Car Parks Ltd v Revenue and Customs, [2019] EWCA Civ 854 -- summary under Consideration

National Car Parks Ltd v Revenue and Customs, [2019] EWCA Civ 854-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration car park machines that did not refund coin payments thereby received extra consideration for VAT purposes The case focused on this hypothetical example. ... In finding that the consideration received by NCP for VAT purposes was £1.50, and rejecting NCP’s submission that £0.10 was a gratuitous payment, Newey LJ stated (at para. 18): English law, of course, generally adopts an objective approach when deciding what has been agreed in a contractual context. ... Words and Phrases consideration ...

Meadow Lake Swimming Pool Committee Inc. v. The Queen, [1999] GSTC 96 (TCC) -- summary under Consideration

The Queen, [1999] GSTC 96 (TCC)-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration town payment of operating loss of civic pool operator was taxable consideration Residents of a town, Meadow Lake, Saskatchewan, formed the appellant to raise funds and build a pool on town property. ... In concluding that these grants were consideration for a taxable supply of management servicers by the appellant, Rowe DJ. stated (at para 20): Pool Committee Inc. received money each year…to utilize the funds solely in connection with the stated purpose of operating, maintaining and regulating the swimming pool…The Town owned the facility and …chose to pay Pool Committee Inc. to run the pool on a day-to-day basis and it received the exact service which was the subject matter of the payment.... ...

Commission Scolaire des Chênes v. Canada, [2002] GSTC 11, 2001 FCA 264 -- summary under Consideration

Canada, [2002] GSTC 11, 2001 FCA 264-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration provincial subsidy was paid only if busing services provided The appellant school boards paid GST charges of independent bus companies for their busing services, and were compensated with a Quebec government subsidy (which was not subject to GST due to provincial government immunity). In finding that the school boards were making taxable supplies to the Quebec government, so that they were entitled to full input tax credits, Noël J.A. stated (at paras. 19, 28): [I]n order for a payment to constitute consideration, it must have been made pursuant to a legal obligation (contractual or otherwise) and must be closely enough linked to a supply that it may be regarded as having been made "for" that supply…. ...

Toronto-Dominion Bank v. Minister of Revenue of Ontario, [1994] OJ No. 897 -- summary under Value of the Consideration

Minister of Revenue of Ontario, [1994] OJ No. 897-- summary under Value of the Consideration Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 1(1)- Value of the Consideration para. ... The Bank applied to the Court for direction as to whether such transfer of legal title to the Bank would trigger land transfer tax under paragraph (f) of the definition of value of consideration. ...

Stewardship Ontario v. The Queen, 2018 TCC 59 -- summary under Consideration

The Queen, 2018 TCC 59-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration statutorily-mandated waste recycling charges were consideration for a taxable supply Stewardship Ontario (“SO”) was a not-for-profit corporation that operated, as part of a regime governed by the Waste Diversion Act, 2002 (Ontario) ('WD Act"), an Ontario program for recycling various types of waste such as paints, solvents, batteries, empty propane tanks and antifreeze. ...

Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794 -- summary under Consideration

Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration consideration for temps included their remuneration The appellants ("Adecco") were employment bureaux supplying clients with temporary staff ("temps") who were not employees of Adecco. ...

OPTrust Amaranth 1 Inc. v. Ontario (Finance), 2016 ONSC 3648 -- summary under Value of the Consideration

Ontario (Finance), 2016 ONSC 3648-- summary under Value of the Consideration Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 1(1)- Value of the Consideration monetized contingent future development obligations were included The Appellants (collectively, "OPTrust") purchased five adjacent parcels of largely-vacant land pursuant to an agreement of purchase and sale (the “Agreement”) dated February 15, 2008. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F - Meaning of Any consideration received by Donee -- summary under Paragraph 118.1(13)(c)

The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ... Consequently, the CRA is of the view that for the purposes of paragraph 118.1(13)(c), the consideration received by the qualified donee for the disposition of a NQS may include the portion of such consideration that is a deemed dividend received by the qualified donee pursuant to subsection 84(3) on a redemption of shares. Words and Phrases consideration ...

24 January 2019 External T.I. 2018-0773301E5 - Paragraph 69(1)(c) and Nominal Consideration -- summary under Paragraph 69(1)(c)

24 January 2019 External T.I. 2018-0773301E5- Paragraph 69(1)(c) and Nominal Consideration-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) a transfer structured as a sales agreement for nominal consideration may qualify as a gift $1 consideration is specified in the legal documentation for a gift of property by a parent to a child solely to ensure the agreement is legally binding. Would s. 69(1)(c) apply, notwithstanding that nominal consideration of $1 would be paid? ... For example, if the agreement governing the transfer provides for consideration of $1 merely to ensure that the agreement is legally binding, the CRA may consider the transfer to be a gift. … If it is determined that the transfer of property was a sale for inadequate consideration rather than a gift, paragraph 69(1)(c) would not apply. ...

30 May 2025 External T.I. 2025-1050201E5 - Part XX Reporting Obligations -- summary under Consideration

30 May 2025 External T.I. 2025-1050201E5- Part XX Reporting Obligations-- summary under Consideration Summary Under Tax Topics- Income Tax Act- Section 282- Subsection 282(1)- Consideration reporting platform operators may be required to infer the consideration paid to platform vendors from the dollar value of their orders The operator (the “Operator”) of a proprietary digital platform (the “Platform”), who was also an equipment manufacturer, allowed independent vendors (the “Vendors”) to list their goods for sale on the Platform to select customers. ... CRA then indicated that, generally, if a particular seller was determined by a reporting platform operator to be a reportable seller, CRA expected the operator to report the information set out in s. 292, including the total consideration paid or credited during each quarter of the reportable period. The CRA reiterated that if the reporting platform operator knew the total value of orders placed with the seller, this could make the seller's consideration "reasonably knowable" to the reporting platform operator as per the definition of consideration. ...

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