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Administrative Policy summary

Ontario Ministry of Finance Calculating Land Transfer Tax -- summary under Subsection 2(1)

Ontario Ministry of Finance Calculating Land Transfer Tax-- summary under Subsection 2(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 2(1) Rate schedule If an agreement of purchase and sale is entered into after November 14, 2016, and registration or the disposition occurs on or after January 1, 2017, the tax rates on the value of the consideration are as follows: amounts up to and including $55,000: 0.5% amounts exceeding $55,000, up to and including $250,000: 1.0% amounts exceeding $250,000, up to and including $400,000: 1.5% amounts exceeding $400,000: 2.0% amounts exceeding $2,000,000, where the land contains one or two single family residences: 2.5%. ...
Administrative Policy summary

23 March 2017 CBA Commodity Taxes Roundtable, Q.18 -- summary under Subparagraph 3(c)(ii)

The same considerations apply to an employee reimbursement. ...
Administrative Policy summary

GST/HST Policy Statement P-045: Butterfly Transactions 9 November 1992 (Obsolete February 2012) -- summary under Section 272

GST/HST Policy Statement P-045: Butterfly Transactions 9 November 1992 (Obsolete February 2012)-- summary under Section 272 Summary Under Tax Topics- Excise Tax Act- Section 272 deemed no-supply on wind-up denies ITC to predecessor In a purported butterfly reorganization, Subco, which operates a department store, transfers its real estate to a newly-incorporated subsidiary (Newco) of its parent (Parent) in consideration for non-voting preference shares, with Newco then being immediately wound-up into Parent and with the real estate being leased to Subco. ...
Administrative Policy summary

June 27, 2000 Interpretation 25236 -- summary under Paragraph 254(2)(a)

A then assigned his rights under the purchase agreement, including rights to a parking stall and locker, and the benefit of the deposits he had made, to B in consideration for a stipulated sum. ...
Administrative Policy summary

Excise and GST/HST News, No. 104, July 2018 -- summary under Paragraph 3(b)

Excise and GST/HST News, No. 104, July 2018-- summary under Paragraph 3(b) Summary Under Tax Topics- Excise Tax Act- Regulations- Taxes, Duties and Fees (GST/HST) Regulations- Section 3- Paragraph 3(b) In general terms, ETA s. 154 excludes provincial sales tax from the consideration on which GST/HST is imposed if the sales tax is imposed at no more than the general sales tax rate for the province. ...
Administrative Policy summary

B-106 Input Tax Credit Allocation Methods for Financial Institutions for Purposes of Section 141.02 of the Excise Tax Act 26 August 2011 -- summary under Direct Input

Some forms relate to taxable supplies for consideration and some forms relate to exempt supplies. ...
Administrative Policy summary

GST/HST Memorandum 3.1, “Liability for Tax” (August 1999) -- summary under Section 133

As a result, the tax applies to any prepayment or part payment of the consideration for a supply even if, at the time payment is made, property has not in fact been transferred or the service has not yet been rendered ...
Administrative Policy summary

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority -- summary under Subsection 2(1)

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) COVID residency relief has not been extended CRA’s COVID-related guidance on corporate residency, permanent establishments, and other similar considerations expired on September 30, 2020, and it has decided not to extend the corporate residency guidance beyond that date, mostly because residency determinations need to be addressed on a case-by-case basis, especially if businesses start adopting new ways of doing business after the pandemic crisis is over. ...
Administrative Policy summary

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998 -- summary under Paragraph 7(d)

It is important that the supplier's understanding of the purpose or objective of the service, as reflected in the contractual agreement with the non-resident customer, be taken into consideration. The supplier's perspective is important because it is the supplier who must determine whether the consideration for the service is zero-rated. ...
Administrative Policy summary

Ontario Ministry of Finance “Non-Resident Speculation Tax” 20 April 2017 -- summary under Subsection 2(1)

Ontario Ministry of Finance “Non-Resident Speculation Tax” 20 April 2017-- summary under Subsection 2(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 2(1) The principal announced features of the "NRST" are: It is a 15% tax that applies effective April 21, 2017 to the value of consideration for the transfer (including a beneficial transfer only) of a residential property in the “Greater Golden Horseshoe” where any of the transferees (e.g., a co-owner) is a foreign entity or taxable trustee. ... Although the Teranet system is not yet set up to collect the NRST, in the meantime all transfers registered after April 20 (and all reporting of beneficial conveyances) must contain a statement acknowledging that consideration has been given to the application of the tax, and the tax must be paid directly to the Ministry of Finance (purportedly even before the legislation is drafted or passed). ...

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