Search - consideration

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). ...

"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). ...