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On a subsequent refund of a portion of the consideration, Corp A also refunds an amount on account of GST but does not issue (or receive) a credit note (or debit note). ...

After ruling that the amounts received by Organizations C from FinanceCo are consideration for a single taxable supply, CRA states: [Organizations C] activities when considered as a whole are predominantly in respect of the promotion and marketing of the Loyalty Program. ...

(l) ("arranging for"), the transaction fees received by ABC from the Lenders are consideration for a service that consists predominantly of credit management services (obtaining Customer credit reports, and checking and authorizing the loans) and services that are preparatory to the provision of financial services (promotion of the program, preparation and processing of loan information, and Lender assistance). ...

Excise and GST/HST News- No. 95 under "-- summary under Subsection 156(2) Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(2) // www.cra-arc.gc.ca/E/pbg/gf/rc4616/README.html ">Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration" 8 April 2015 Specified members of a qualifying group that have existing elections, each with a different effective date that is before January 1, 2015, have the following two options for filing Form RC4616: Under simplified procedures developed by the CRA, specified members of a qualifying group that have existing elections, each with a different effective date that is before January 1, 2015, now only need to file one Form RC4616 indicating December 31, 2014 as the effective date (covering all members instead of each filing separately). ...

The consideration is the assumption of an existing mortgage and payment of cash. ...

.-- summary under Subsection 80.01(4) Summary Under Tax Topics- Income Tax Act- Section 80.01- Subsection 80.01(4) Proposed transactions Holdco, a CBCA corporation, will transfer its note (the Opco note) of Opco (its wholly-owned CBCA subsidiary) to a newly incorporated CBCA subsidiary of Opco (Subco) for the Opco note's fair market value (which is less than its principal amount) in consideration for the issuance by Subco of the Subco note. ...

The recipient, Developer A, pays an amount as consideration for the project and another amount that is clearly stated in the sale documents to be the GST/HST paid by the recipient and collected by the supplier, Developer B, in respect of this taxable supply of real property. ...

Update- Competent Authority Services Division, 20 December 2013-- summary under Subsection 247(10) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(10) using MAP Where a Canadian entity requests a reduction of its Canadian taxable income (downward transfer pricing adjustment) where the request relates to a self-initiated (that is, not initiated by a tax authority) adjustment to increase the income of a related entity in another country (upward adjustment), the Canadian competent authority will accept the case under the Mutual Agreement Procedure in these circumstances: The upward adjustment has been accepted for consideration by the foreign tax authority; The foreign competent authority tries to resolve the case under the MAP. ...

Where the registrant who acquires the continuous transmission commodity from the first buyer is not acquiring the commodity for consumption, use, or supply exclusively in the course of commercial activities of the registrant, the supply is an imported taxable supply and the registrant is liable for tax under sections 218 and 218.1, calculated on the value of the consideration for the supply of the commodity. ...

All possible benefits accruing to members must be taken into consideration in determining the tax status of a membership. ...