Search - consideration

In order to ensure consideration of a treaty-based waiver application, it should be submitted at least 30 days prior to the commencement of the services in Canada or 30 days prior to the initial payment for the related services. ... Non-residents providing services through corporations, partnerships, or joint ventures or who have done so in the past, will be reviewed under the guidelines taking into consideration the total of their services provided in Canada in the period both as an individual, and through the corporation, partnership or joint venture. ... The geographic area to consider is relative to the industry and type of activity under consideration. ...

However, this subparagraph will only apply if the taxpayer settles or extinguishes all debt obligations for consideration that does not include any unit, interest, share, or debt obligation of: (a) the taxpayer; (b) any person with whom the taxpayer does not deal at arm's length; or (c) any partnership or trust of which the taxpayer or a person described in (b) above is a member or beneficiary. ... Subsection 18(9.1) deals with the deductibility of fees paid to a person or partnership to reduce the interest rate on a debt obligation, or as penalties or bonuses in consideration for the repayment of all or a portion of a debt obligation prior to its maturity. ... However, subsection 18(9.1) does not apply to any fee, penalty, or bonus that: may reasonably be considered to have been paid for the extension of the term of a debt obligation or as consideration for the substitution or the conversion of a debt obligation into another debt obligation or into a share; is contingent or dependent upon the use of, or production from, property; is computed by reference to revenue, profit cash flow, commodity price, or any similar criterion; or is computed by reference to any dividends paid or payable on any class of shares in a corporation. ...

Admission (consideration for the ticket) to the dance is exempt under section 3 of Part III of Schedule V as the dance is an extra-curricular activity organized under the authority and responsibility of the school authority and the supply is made by the school authority primarily to students of the school. ... Section 7.1 of Part III of Schedule V exempts, in part, “a supply of a service or membership the consideration for which is required to be paid by the recipient of a supply included in section 7 [of Part III of Schedule V] because the recipient receives the supply included in section 7” (for example, instruction in courses offered by a school authority for which credit may be obtained toward a diploma). 25. Examples of the supplies referred to in section 7.1 of Part III of Schedule V include supplies of various student club memberships where the consideration for these supplies must be paid by students because they receive a supply that is exempt under section 7 of Part III of Schedule V. 26. ...

A bonus or premium paid by a mortgagor to a mortgagee in consideration for the mortgagee's consent to an early redemption of the mortgage is considered to constitute an amount paid to a creditor on account or in lieu of payment of any debt and consequently this premium or bonus cannot qualify as an "eligible capital expenditure"; (d) amounts paid or payable by a corporation to a person in his or her capacity as a shareholder. ... Where goodwill, as a recognizable asset, is acquired by the purchaser of a business in the circumstances described in ¶ 6, the consideration given for the goodwill, as well as any legal and accounting fees that can be directly associated with the purchase of the goodwill, will qualify as an eligible capital expenditure. If the portion of the total consideration for the business that is allocated to the goodwill is unreasonable, or if the goodwill has a value which the vendor and purchaser have not specified, the Canada Revenue Agency (CRA) can apply the provisions of section 68 to deem what may reasonably be regarded as the amount for the goodwill. ...

However, this is an area where fact-patterns are likely to vary and a variety of considerations may apply. ... Has consideration been given to a potential adverse impact on the charity's reputation from its commercial operations? ... Is the activity commercial in nature—that is, does the charity derive revenue in consideration for the provision of goods or services? ...

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. ... The monthly fee is consideration for a supply of a service that includes accommodation and assistance with personal hygiene, grooming, and dressing. ... If a transaction consists of multiple supplies, it is necessary to determine whether one of those supplies is incidental to another and whether it may consequently be deemed to form part of a single supply pursuant to other provisions of the Act (such as section 138, which applies where the main and the incidental supplies are made for a single consideration). ...

When determining if land that is capital real property of an individual or personal trust is used primarily in a business rather than primarily in non-business uses immediately prior to its sale, consideration must be given to all uses of the land throughout the time it is owned by the individual or personal trust. 4. ... However, consideration should be given to possibility of section 196.1 applying in such circumstances Footnote 16. ... Footnotes Footnote 14 In the absence of legal restrictions such as minimum lot size or functional considerations such as needing additional land for road access, the amount of land considered to form part of the residential complex, i.e., the amount of land considered to be reasonably necessary for the use and enjoyment of the residential unit as a place of residence, would be restricted to a half hectare. ...

Section 156 provides a joint election that permits corporations resident in Canada and Canadian partnerships that are qualifying members of a qualifying group to treat certain taxable supplies between them as having been made for nil (or no) consideration if the requirements for the election are satisfied. ... For information about this election, refer to GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, and Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes. ...

The joint election under subsection 156(2) permits two Canadian partnerships or a Canadian partnership and a corporation that is resident in Canada that are specified members of a qualifying group to treat certain taxable supplies between them as having been made for nil (or no) consideration. For information about the definitions of specified member and qualifying group, refer to GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration. 3. For information about this joint election and the conditions for being a specified member of a qualifying group, refer to GST/HST Memorandum 14-5 and Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes. 4. ...

In cases where one of the main purposes of a person's absence from Canada is to avoid Canadian taxes, which would otherwise be payable, consideration may be given to other factors in determining the person's residence status. ... However, because each province has its own guidelines and policy regarding eligibility for benefits after leaving Canada, continuing coverage under a provincial plan will not be considered to be a significant residential tie, but will be given consideration when reviewing all the facts.) the registration of property that is being taken outside Canada with Canada Customs; the rental of a safety deposit box or postal box in Canada; the listing of a telephone number in a telephone directory in Canada; the continued use of stationery and business cards with a Canadian address; and professional or other memberships in Canada (on a resident basis). 25. ... The value of consideration for these supplies is deemed to be the fair market value of the supply at the time the property is transferred or the service is rendered. ...