Search - consideration

After ruling that the bank is providing a (single) supply of a taxable service to the insurer in consideration for payments to it by the insurer, CRA stated:...the activities undertaken by the Bank are the promotion of the insurance policy offered to Cardholders...as well as forwarding the applications for Certificates under the Group Policy for issuance by the Insurer. ...

Income Tax Technical News, No. 34, 27 April 2006 under "Sale of Tax Losses"-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) avoidance of same or similar business restriction Where Profitco avails itself of the benefit of tax losses of Lossco, a publicly traded corporation that is insolvent and has ceased to carry on its business, by transferring assets to Lossco in consideration for shares that represent only 45% of the votes but substantially all the value of Lossco, CRA would consider the application of GAAR. ...

Proceeds Proceeds...means the fair market value, and includes all consideration, such as cash, debt obligations, and shares, that is paid or payable to the transferor. ...

., p. 44: 13:...it is the department's view, after giving consideration to the intention of subsections 87(8) and (8.1), that the "new foreign corporation" referred to in those subsections would include the surviving entity of an absorptive merger in the United States. ...

The amount calculated under corporate law is usually referred to as the "stated capital" of the class of shares.... 3 In regard to the issuance of shares, the stated capital account reflects (a) the par value of shares issued with a par value, (b) the amount ascribed by the directors for shares issued without par value or, in some jurisdictions, the fair market value of the consideration received for shares issued without par value... ...

GST/HST Technical Information Bulletin B-068 "Bare Trusts" Amended 10 January 2005-- summary under Section 269 Summary Under Tax Topics- Excise Tax Act- Section 269 transfer of registered title by (or to) bare trustee generally is for nil consideration After discussing whether there is a bare trust, CRA stated: [S]ections 268 and 269 of the Act provide that, for GST purposes, there will be a supply when any property, including the legal estate, is settled with a trustee or distributed to the beneficial owners, even if this is not a disposition for income tax purposes. ...

Therefore, the Loyalty Points awarded to customers as a result of consumption of telecommunication services, on special occasions such as birthdays, or upfront based on the expectation of future consumption of telecommunication services can be viewed as a coupon upon redemption; the awarding of the points to customers is considered a taxable supply that does not attract GST/HST where there is no consideration charged to the customers for the supply. ...

" The letter previously noted that "although there is no rule deeming the bank to be resident in Canada, many of the considerations that led to such a rule in the context of Part XIII tax are relevant here as well: the bank's business is carried on in Canada, and a person making a payment to the bank cannot always be presumed to know the details of the bank's situation. ...

Consideration will not be given to waive a portion of the penalty as either the entire amount or no amount will be waived. ...

8 February 2005 Interpretation Case No. 52141-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) stock options valued based on in-the-money value Respecting the issuance of stock options to an independent contractor as additional compensation for services rendered, CRA stated: [W]here a person receives a stock option enabling the person to purchase shares for an amount less than the fair market value of the shares as part of the compensation paid to him or her by the corporation for taxable services provided (or to be provided) to the corporation, the CRA will consider the difference between the purchase price of the shares under the option and the fair market value of the shares at the time of the granting of the option to be additional consideration for the contractor's services to the corporation. ...