Search - consideration

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. ...

30 December 2013 Ruling 136499-- summary under Subsection 272.1(1) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(1) distributions to GP of portion of LP set-up fees were taxable A limited partnership (the “Partnership”) engaged in lending money and received “Set-Up” fees from the borrower, which were considered by CRA to be part of the consideration for its supply of financial services. ...

29 November 2004 Interpretation 54669-- summary under Subsection 186(1) Summary Under Tax Topics- Excise Tax Act- Section 186- Subsection 186(1) Holdco required to allocate inputs but eligible for ITCs on inputs in free supplies to Opco In responding to a question on the application of s. 186(1) to inputs used by a holding company partially for making supplies of administrative services for consideration to related corporations whose debt or shares are held by it, CRA stated: [I]f a holding company acquires or imports property or a service or brings it into a participating province for consumption or use partially in relation to the shares or indebtedness of a related company and partially in relation to other activities of the holding company, the costs should be allocated pursuant to the rules in the ETA governing ITC eligibility. ...

However, where a person provides property or a service to a person for no consideration but receives interest or dividend revenue from that person it is unlikely that ITCs would be available as a result of the application of subsection 141.01(4). ...

26 February 2015 CBA Roundtable, Q. 20-- summary under Paragraph 128(1)(a) Summary Under Tax Topics- Excise Tax Act- Section 128- Subsection 128(1)- Paragraph 128(1)(a) only fully-voting shares taken into account Does the 90% test in s. 128(1)(a) only take into consideration shares that have “full voting rights under all circumstances” in both the numerator and the denominator? ...