Search - consideration

X subsequently receives consideration to transfer that interest to builder (the Vendor), Mr. ...

However, section 232 does appear to offer a solution where the consideration is reduced. ...

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. ...

CRA indicated that Univar signifies that, in the context of a consideration of the general anti-avoidance rule, there can be an examination of what the taxpayer could have done versus what the taxpayer did do – but CRA is examining what limitations should be placed on this approach. ...

28 February 2019 CBA Roundtable, Q.8-- summary under Paragraph 7(f) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 7- Paragraph 7(f) soliciting orders for Canadian customer of NR did not oust zero-rating A registered non-resident (NR) does not itself have any presence in Canada but uses a resident (sub)contractor (RC) to provide marketing and soliciting services (in the credit card processing line of business) to a resident Canadian company in consideration for commissions. ...

CRA responded We are currently reviewing the extent to which the Medallion decision would affect our position with respect to the issue of who can be considered to be a participant in a joint venture for purposes of section 273 of the ETA, and this includes taking into consideration the issue described in the question. ...

What are the relevant considerations? After indicating that it avoids bright-line tests in order to avoid accommodating tax avoidance techniques, CRA indicated that, broadly speaking, taxpayers should be prepared to illustrate how the location and timing of the board meetings were necessary from a business corporate governance perspective and not intended to exploit the relief in the Guidance for tax avoidance purposes. ...

As a result of the proposed amendment, where an assignment agreement is entered into after May 6, 2022, the GST/HST applies to assignment sales that were not otherwise taxable, and the amount attributable to a deposit is excluded from the consideration for all taxable assignment sales. ...

Where Advisor A sells an insurance brokerage business to Advisor B, with Advisor B being assigned the entitlement to future streams of commissions including renewal commissions generated as a result of sales to clients previously made by Advisor A, such commissions would not be exempt consideration in the hands of Advisor B as Advisor B had no direct involvement with the clients in arranging for the supply to them of the insurance policies. ...

[W]here the principal and associate have entered into a bona fide arrangement to share the fees from the associate's supplies of exempt naturopathic services, the payment made by the associate is treated as an apportionment of fees between parties and not as consideration paid to the principal for a supply.... ...