Search - consideration

Tratyu for payments for the use of or right to use know-how, but not for the provision of services, and before referring to the OECD Commentaries on this distinction, CRA stated: The distinction between know-how and other royalties/services is not always clear so it is important to give special consideration to these types of transactions between non-arm's length parties in Canada and the United States. ...

As a general rule, the drop-shipment rules address this issue by deeming the registrant in a drop-shipment situation to have made a supply of the goods to the non-resident recipient for consideration equal to their fair market value when the registrant transfers physical possession of the goods in Canada to another person on behalf of the non-resident or to the non-resident. ...

Parties to an existing election with an effective date before January 1, 2015 that is still in effect on January 1, 2015, will also be required to file Form RC4616 to treat certain supplies made between them after 2014 as having been deemed to be made for nil consideration. ...

For the purposes of paragraph 85(3)(c) the partnership must not own any property immediately before the winding up other than property received from the corporation as consideration for the disposition or money. ...

As a result of the reorganization, FA2 transfers some of its assets for no consideration to FA3 and FA3 issues shares to the shareholders of FA2 pro rata based on the number of shares they hold in FA2. ...

As a result of the reorganization, FA2 transfers some of its assets for no consideration to FA3 and FA3 issues shares to the shareholders of FA2 pro rata based on the number of shares they hold in FA2. ...

In indicating that the reimbursements likely would be consideration for the supply of a separate service by Landlord, CRA stated: There is nothing in the MOU that provides that the amount paid by the Tenant to the Landlord are to be treated as rent for purposes of the Lease Agreement, nor is there any suggestion that failure to pay the amount would result in a default under the Lease Agreement. ...

Subsection 165(1) does not apply to the situation, because the damage payments are not consideration for a supply. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 17-- summary under Specified Derivative Supply Summary Under Tax Topics- Excise Tax Act- Section 217- Specified Derivative Supply b(i) and (ii) are mutually exclusive S. 217(b)(i) of the definition of "specified derivative supply" states that the "all or substantially all of the value of the consideration is attributable to any error or profit margin, or employee compensation or benefits, reasonably attributable to the supply" and s. 217(b)(ii) of the definition states that the amounts are not loading. ...

If the supplier had claimed an ITC for the tax on the importation of the goods, there will be no penalty and interest consequences if the supplier had also collected the tax on the deemed value of the consideration for the supply when it became payable (as if the supply made at that time had in fact been made in Canada and been subject to tax), accounted for it in its net tax and remitted any resulting net tax remittable when required. ...