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The third party’s supply of the consulting service to Financial Institution D is an exclusive input of Financial Institution D because it is not an excluded input and it is acquired by Financial Institution D for consumption or use directly and exclusively for purposes other than making taxable supplies for consideration (that is, to make exempt supplies of financial services). ...

Foreign Income Verification Statement April 14, 2021-- summary under Specified Foreign Property Summary Under Tax Topics- Income Tax Act- Section 233.3- Subsection 233.3(1)- Specified Foreign Property Specified foreign property is defined in subsection 233.3(1) of the Income Tax Act and includes: funds or intangible property (patents, copyrights, etc.) situated, deposited or held outside Canada tangible property situated outside Canada a share of the capital stock of a non-resident corporation shares of corporations resident in Canada held outside Canada an interest in a non-resident trust that was acquired for consideration an interest in a partnership that holds a specified foreign property unless the partnership is required to file Form T1135 a property that is convertible into, exchangeable for, or confers a right to acquire a property that is specified foreign property a debt owed by a non-resident, including government and corporate bonds, debentures, mortgages, and notes receivable an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include: a property used or held exclusively in carrying on an active business a share of the capital stock or indebtedness of a foreign affiliate an interest in a trust described in paragraph (a) or (b) of the definition of exempt trust in subsection 233.2(1) a personal-use property as defined in section 54 an interest in, or a right to acquire, any of the above-noted excluded foreign property ...

The payment attributable to the billing period is deemed to be consideration payable for the supply of the service for that billing period. 76. ...

Therefore, for all taxable supplies of short-term accommodation made in Vancouver during the effective period, the GST will be calculated on the total value of the consideration paid or payable for the accommodation, including the amount of the PST, the MRDT, and the Major Events MRDT. ...

Size and penalties The Transfer Pricing Review Committee (TPRC) takes the size of the taxpayer and the size of the transaction into account in determining whether to penalize, although these are only a factor in the consideration. ...

25 February 2016 CBA Roundtable, Q. 4-- summary under Subsection 317(3) Summary Under Tax Topics- Excise Tax Act- Section 317- Subsection 317(3) tax debtor still required to remit GST/HST on garnished receivable/provincial garnishment limits respected only in Quebec Where an account debtor receives a Direction to Pay under s. 317 respecting the GST/HST indebtedness of a registrant that had made the related taxable supply to the account debtor, (i) how should the account debtor treat the GST/HST portion of the amount owing by it for the supply, (ii) should it pay the tax and consideration to CRA, and (iii) how does the supplier account for the GST/HST on the payment in remitting its net tax for the applicable reporting period if that amount has been paid by the account debtor pursuant to the garnishment? ... A portion of the payment cannot be allocated to the amount that the tax debtor is required to pay on the next remittance due date as the funds were recovered by way of a Requirement to Pay in respect of the tax debtor’s pre-existing GST/HST liabilities. 4(a)(ii) [Payment of garnished amount satisfies 3 rd party’s liability] [I]f the amount owed to the CRA by the tax debtor exceeds the amount of the consideration for the supply [and] the related GST/HST…then the total amount payable by the third party to the tax debtor must be paid to the Receiver General. ...

It is not uncommon for a shareholder to request an S Corporation agreement and, while the request is under consideration, file the Canadian returns in the expectation that an S Corporation agreement will be provided. ...

Canco acquires preferred shares of FA for nominal consideration, and receives thereon a distribution of FA's exempt earnings- in order that on the subsequent sale of the FA common shares, Canco can realize a loss which will offset a FX gain on repayment of Canco's debt. ...

Where property is supplied by way of lease, licence or similar arrangement, and consideration is paid on a periodic basis (lease interval), a separate supply is deemed to occur in respect of each lease interval. ...

. … Since B Co already owns the logs, the amounts paid by B Co are not consideration for a supply of logs by A Co but would appear to be [taxable] compensation paid to A Co for cutting the timber. ...