Search - consideration

Pursuant to subsection 123(1), "improvement", in respect of property of a person, means any property or service supplied to, or goods imported by, the person for the purpose of improving the property, to the extent that the consideration paid or payable by the person for the property or service or the value of the goods is, or would be if the person were a taxpayer under the Income Tax Act, included in determining the cost or, in the case of property that is capital property of the person, the adjusted cost base to the person of the property for the purposes of the Income Tax Act. ... A rebate shall not be paid to a person under section 257 in respect of a taxable sale of real property made by the person unless the person files an application for the rebate (i.e., the GST189) within two years after the day the consideration for the supply of the real property became due or was paid without having become due. ...

Explanation Ruling #1 Since the Church's requirement to pay the Latecomer fees (XXXXX) is set out in the First and Second Agreements as a condition precedent for the issuance of a building permit or development permit, the Latecomer fees are regarded as consideration for the supply of a permit. ... However, the Church is entitled to claim a rebate under section 261 for the tax paid in error to the City in respect of the Latecomer fees which are consideration for an exempt supply. ...

In this same principle, it states “In addition to income and debt service coverage, FRFIs should take into consideration, as appropriate, other factors that are relevant for assessing credit risk, such as the borrower’s assets and liabilities (net worth), other living expenses, recurring payment obligations, and alternate sources for loan repayment”. ... [GST/HST] remittance for non-registrants After careful consideration of the facts surrounding the sale and the information provided above, should it be determined that the assignment sale is a taxable sale of real property, then the [GST/HST] will need to be remitted to the CRA. ...

Qualifying funding Subsection 259(1) defines "qualifying funding" of the operator of a facility for all or part of a fiscal year of the operator as meaning a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property or services that are made available or rendered at the facility during the fiscal year or part and is paid or payable by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ...

In circumstances where a supply of a nursing service is exempt under section 6, the consideration for that supply, i.e., the "charge" referred to in paragraph 14 of G300-4-2, will not be subject to the GST/HST. ... The fee paid by the hospital is considered to be part of the consideration for the supply by the Company to the hospital. ...

Below are sample invoices, attached to your email, that were submitted for our consideration. The invoices provide a brief description of the supplies acquired by [X] and include the consideration and tax applicable for those supplies: […] RULING REQUESTED You would like to confirm that paragraphs 186(1)(a) and (c) apply to allow [X] to claim input tax credits (ITCs) for the GST/HST paid or payable by [X] on the supplies described on the sample invoices. ...

Furthermore, XXXXX would not be required to collect GST/HST on the reimbursement of the expenses where it is established that the expenses were either incurred by XXXXX as an agent of XXXXX or they represent consideration for zero-rated services. 1. ... Generally, the "recipient" of a supply is defined under subsection 123(1) of the ETA as the person who is liable to pay the consideration for the supply. ...

For example, this would occur where all square meters of the CRP are not equal in terms of expressing the extent of use of the CRP in commercial activities or where there are time-based considerations. ... Since there are distinct areas of the parcel used in commercial activities and non-commercial activities and there are no time-based considerations (i.e., the distinct areas of the parcel are dedicated exclusively to one use at all times), the space-based method cannot be considered unreasonable unless it can be shown that a unit of space is not a consistent measure of the extent to which the parcel is used in commercial activities. ...

XXXXX the Agreement provides that the Total Basic Fee is consideration for the right to occupy the suite and for the residential services and facilities, XXXXX, meals and other items identified XXXXX. ... Consideration is separately identified such that a resident knows the amount paid for accommodations, XXXXX services and meals, and other charges. ...

All possible benefits, both direct and indirect, accruing to members must be taken into consideration in determining the tax status of a membership. ... These are not insignificant discounts when compared to the consideration for membership in XXXXX. ...