Search - consideration

[W]here...a debt was of a kind that would have qualified for consideration as a bad debt had it been retained until the end of the taxation year, any loss at the time of its disposition, or later because of non-payment by the debtor, would normally be deductible by the taxpayer as a general business expense. ...

8 February 2005 Interpretation Case No. 52141-- summary under Paragraph (d) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (d) subsequent exercise of stock option by independent contractor entailed exchange of financial services Respecting the issuance of stock options to an independent contractor as additional compensation for services rendered, CRA indicated that the in-the-money value of the options at the time of grant would represent the amount of such additional consideration for the services, and then stated: With respect to the exercise of the stock options (share purchase) and subsequent sale of the shares, it is our view that these are each supplies of a "financial service" as defined at paragraph 123(1)(d) of the ETA. ...

After noting that s. 183(1) could apply in a default scenario, CRA stated: If subsection 183(1) does not apply, it is a question of fact whether there would be a supply of the property from the Purchaser to [FinanceCo], whether there is consideration payable for the supply, and the GST status of the supply. ...

After referring to Policy Statement P-243 "Promotional Allowances," CRA stated: Whether any particular price difference may be either a reduction in consideration under subsection 232 or a promotional allowance which is subject to section 232.1, would be determined by a review of the related documentation. ...

14 December 1992 Memorandum (Tax Window, No. 30, p. 4, ¶2488)-- summary under Subsection 110.6(7) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(7) S.110.6(7)(b) will not apply to a transaction or a series of transactions intended to make shares of a company qualify as qualified small business corporation shares, provided that during the course of the purification reorganization, a property has not been acquired by a corporation for consideration that does not approximate its fair market value. ...

27 February 2001 Interpretation 33200-- summary under Subsection 153(1) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(1) calculation of lese consideration where lease assigned A car lease agreement is assigned to another lessee of the lessor ("Leaseco") pursuant to an Assignment and Assumption Agreement. ...

C in consideration for a cash payment representing the fair market value of the obligation, including a "reverse premium" representing the discounted value of the excess interest differential, Co. ...

Where there is a supply of resort points (a form of intangible personal property) relating to real property situated in and outside Canada, it is the position of CRA that GST will apply (including on a sale by a U.S. or other non-resident entity) only to the extent that the intangible personal property relates to real property in Canada at the time consideration for the intangible personal property becomes due. ...

17 May 2012 Interpretation File 97556-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service The Supplier, which purchases point-of-sale terminals from CanCo and sells them to merchants, also markets processing services to the merchants, whom it refers to CanCo, in consideration for fees paid by CanCo. ...

In responding negatively, CRA stated: [I]t is unclear how BCo could be considered to have charged and collected the consideration and tax payable from itself in respect of a supply made by ACo as required under subsection 177(1.11). ...