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Administrative Policy summary

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025 -- summary under Clause 6(2)(b)(i)(A)

However, any address of the recipient obtained in the ordinary course of business of the supplier should be taken into consideration in applying the rule. ...
Administrative Policy summary

17 June 2025 STEP Roundtable, Q.12 -- summary under Paragraph 55(2.1)(c)

Opco then transferred Asset 2 to Newco in consideration for Newco shares with an ACB, PUC and FMV of $1,000. ...
Administrative Policy summary

GST/HST Technical Information Bulletin B-105 February 2011 "Changes to the Definition of Financial Service" -- summary under Paragraph (l)

(l), as “the services provided by MBCo in these circumstances, viewed as a whole, go beyond mere preparatory services described in paragraph (r.4)”); Example 10 (referral fees received by an unlicensed consultant for referring applicants, along with completed application forms, to a licensed mortgage broker (which itself is the one dealing with the lenders) are taxable); Example 11 (an individual, whose only business is as a self-employed insurance agent, earns exempt commissions from a distributor of insurance policies of an insurer in consideration for soliciting purchasers, submitting the policy application directly to the insurer and advising on the client’s coverage from time to time). ...
Administrative Policy summary

Dual-purpose payments -- summary under Subsection 6(3)

Because the payment is provided for in an agreement made during employment in consideration for what the employee is not to do after the end of employment, subsection 6(3) deems the payment to be employment income. ...
Administrative Policy summary

26 February 2015 CBA Roundtable, Q. 16 -- summary under Subsection 240(1)

However, as a result of making the joint venture election, Company C will not include consideration from taxable supplies deemed to have been supplied by Company A on its behalf in the course of the joint venture activities when determining if it has exceeded the small supplier threshold under section 148 of the ETA unless Company A is an associate. ...
Administrative Policy summary

15 December 2017 Information Circular - IC00-1R6 - Voluntary Disclosures Program -- summary under Subsection 220(3.1)

Given the complexity of transfer pricing issues, applications relating to transfer pricing matters will be referred to the Transfer Pricing Review Committee for their consideration under subsection 220(3.1) ...
Administrative Policy summary

GST/HST Memorandum 20-5 “School Cafeterias, University and Public College Meal Plans, and Food Service Providers” December 2019 -- summary under Section 13

The CRA considers top‑ups or the addition of funds to a qualifying meal plan to be additional consideration for the same supply. ...
Administrative Policy summary

CRA Update on "S. 55(2) and Safe Income - Where Are We Now?" -- summary under Paragraph 55(2.1)(c)

When a corporation realizes the accrued gain, on a property that it had acquired on a rollover basis in consideration for preferred shares, on disposing of that property, that gain is now considered to contribute to the gain on those preferred shares, so that such gain is to be included in the safe income of the preferred shares. ...
Administrative Policy summary

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 -- summary under Subsection 188.2(5)

Furthermore, in these circumstances, where any amounts are deducted by the pool operator from the payment made to the person, the consideration for the person's supply to the pool operator would be the payment less the deducted amount unless there is clear indication under the arrangements between the parties that the reduction is in respect of a supply made by the pool operator to the person. ...
Administrative Policy summary

GST/HST Memorandum 21-1 “Child Care Services“ December 2019 -- summary under Section 1

From the fees paid to it, the organization keeps a 5% commission for the administrative services it provides and pays the remaining amount to the child care provider as consideration for the child care services that the organization acquires. ...

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