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What are the policy considerations in this situation? Finance responded: The reduction in the value of a gift is calculated on an individual basis for each taxpayer. ...

This means that ParentCo would be required to take into account SubCo’s consideration from taxable supplies over its previous four calendar quarters when determining whether it is required to register for GST/HST purposes. … Under subsection 240(2.1), ParentCo would be required to apply for GST/HST registration before the thirtieth day after the day it makes its first taxable supply in Canada. ...

Consequently, it is our view that the adjustment for the amount equivalent to the portion of the property taxes that relates to the period during which the purchaser will be the owner of the real property is additional consideration for the supply of the real property. ...

However, gross negligence penalties may be considered based on the materiality of the error or where the registrant was previously advised of penalty consideration for similar conduct. ...

B-106 Input Tax Credit Allocation Methods for Financial Institutions for Purposes of Section 141.02 of the Excise Tax Act 26 August 2011-- summary under Non-Attributable Input Summary Under Tax Topics- Excise Tax Act- Section 141.02- Subsection 141.02(1)- Non-Attributable Input Employee surveys re environmental practices, or employee assistance programs, are non-attributable inputs Example 27 Financial Institution G makes both taxable supplies for consideration and exempt supplies. ...

Regarding whether such adjustments should be regarded as being to the purchase price for the real estate, so that normally no GST/HST should be charged on such adjustments (based on the ETA ss. 221(2) and 228(4) self-assessment rule or a residential real estate exemption), CRA treated this as essentially a question relating to an application of the single-supply doctrine, so that “if an obligation is inextricably tied to the real property itself, then it is likely not a separate supply from the sale of the real property and the adjustment likely increases or decreases the value of consideration” for the real estate, whereas “if it is determined that an obligation giving rise to the adjustment is a separate supply from the sale of the real property that is not incidental to the sale of the real property, then the application of the GST/HST to the adjustment depends on the nature of the separate supply itself.” ...

The Tax Policy Branch will recommend to the Minister that, effective for taxation years of foreign affiliates ending after 2016, s. 95(2)(b)(i)(B)(I) not apply respecting income of a foreign affiliate (''FA1") of a taxpayer from the provision of services, to the extent that conditions generally analogous to those in s. 95(2)(a)(ii)(D) are satisfied, including: The income derives from amounts paid or payable by another foreign affiliate (''FA2") of the taxpayer in consideration for the services; The amounts paid or payable are for expenditures incurred by FA2 for the purpose of gaining or producing income from property; The property is shares of another foreign affiliate ("FA3") that are "excluded property" of FA2 (as defined in subsection 95(1)); and The Canadian taxpayer has a "qualifying interest" (as defined in paragraph 95(2)(m) of the Act) in FA1, FA2 and FA3. ...

Rather, the reimbursements would be consideration for a supply. "In relation to" 21. ...

NR Target sells the shares of CanOpco (which are not taxable Canadian property) to CanAc in consideration for a Note Receivable. ...

[T]he terms of an agreement (that is, the treatment agreed upon and reflected in an invoice) between an acupuncturist and patient establish what the acupuncturist is agreeing to provide and what the patient is expecting to receive for the consideration paid. ...