Search - consideration

"6363-1 Foreign Affiliate- Specified Member of Partnership")-- summary under Specified Member Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Specified Member "A person is actively engaged in the business of a partnership for the purposes of the definition of 'specified member' in subsection 248(1) of the Act, where that person is directly involved in the management and/or the daily activities of the business and where that involvement takes place on a regular, continuous and substantial basis throughout the period under consideration.... ...

The amount payable by a developer to the municipality as its proportionate share of the improvement costs also would generally be regarded as consideration for an exempt supply under s. 20(c). ...

1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Where a non-treaty country subsidiary of a Canadian corporation manufactures or process goods outside Canada with no purchasing or processing of raw materials taking place in Canada, and it appoints its Canadian parent as agent to sell its products in Canada as well as outside Canada in consideration for a sales-based commission and with authority granted to its parent to negotiate and conclude sales contracts in its name, RC will ignore the agency relationship with the parent and consider the subsidiary to have Canadian business income equal to all income from Canadian sales of its product minus costs incurred to earn that income. ...

ATR-36 (4 Nov. 88)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) Favourable rulings (but with a refusal to give more than an opinion, in compliance with IT-169, as to the efficacy of a price-adjustment clause) are given for an estate freeze transaction in which: X transfers his pre-1972 common shareholding in a public company to Holdco in consideration for a promissory note and redeemable retractable non-cumulative shares which cease to be voting on his death and with the usual asset-depletion protections; a family trust for adult beneficiaries pays $5,000 in subscribing for common shares of Holdco; and the adult children of Holdco subscribe for non-voting non-cumulative redeemable Class B shares of Holdco for an aggregate subscription price of $50,000 (in order to provide Holdco with the funds to pay dividends on its shares). ...

After noting that under s. 136.1(1), Aco was required to account for the supply of property made by it, CRA went on to state: If in fact Bco is making supplies in the half-month period for no consideration payable by the lessee or the recipient, then Bco is not required to collect GST/HST from the lessee or recipient unless the non-arm's length rules under [s.] 155(1). ...

GST/HST Technical Information Bulletin B-032 “Expenses Related to Pension Plans” 17 November 2015-- summary under Subsection 172.1(5) Summary Under Tax Topics- Excise Tax Act- Section 172.1- Subsection 172.1(5) imputation of a supply of an investment management service by employer to RPP where the fee was incured by the employer CRA seemed to consider that where an employer retains an investment manager for the company pension plan, and the pension plan pays the manager directly, CRA considers there to be a double supply of a service from the manager to the employer, and by the employer to the plan Where a pension-related expense incurred by an employer has been paid for out of plan trust assets, the CRA generally considers the amount of the payment made by the plan trust to be consideration for a supply of property or a service made by the employer to the plan trust where any of the following occurs: the plan trust paid the third party supplier directly, the employer invoiced the plan trust for the expense, the plan trust reimbursed the employer. ...

8 January 2016 Interpretation 150125-- summary under Property Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Property agreement to be available to supply services was a supply of property A stipend paid by a hospital to a medical specialist for agreeing to stay close to the hospital so as to be available on an on-call basis was taxable consideration for the supply of property to the hospital rather than for a supply of an exempt medical service. ...

Are the fees charged by a regional municipality to the land owner deemed to be consideration for an exempt supply under s. 189.1? ...

For example, a university whose predominant purpose is education and research would generally not acquire its main campus over 40% for the purpose of making taxable supplies for consideration. ...

The [recipient] definition refers to ‘consideration for the supply’. However, in the present case, the [Lessor] has not acquired any supply of software licences, and is therefore not entitled to claim any ITC for the tax paid for them. ...