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Current CRA website
Financial Claim Review Manual – Review Procedures for Financial Reviewers
This is an important consideration for demonstrating the extent to which the issues were communicated to the claimant by the FR, and the efforts to work with the claimant to resolve these issues. ... The FR needs to take into consideration the CRA service standards when planning and conducting a review. ... Consideration of penalties must be discussed with the FRM in all cases. ...
Current CRA website
Information for crypto-asset users and tax professionals
Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...
Current CRA website
Information for crypto-asset users and tax professionals
Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...
Current CRA website
GST/HST and place of supply rules
Lease intervals – Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Examples- When the province in which the greatest proportion of the Canadian rights can be used cannot be determined Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a movie chain's five cinemas situated in Nova Scotia and New Brunswick. ... Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...
Technical Interpretation - Internal
30 July 2004 Internal T.I. 2004-0072531I7 - Tax shelters - penalties
Consideration Black's Law Dictionary defines consideration, in part, as follows. ... Thus, in a contract of sale, the money paid or agreed to be paid by the purchaser is the consideration to the vendor, and the property sold is the consideration to the purchaser. ... It is thus our opinion that these loan elements would not constitute consideration. ...
Ruling
2021 Ruling 2021-0911211R3 - Foreign Takeover
Payment of Merger Consideration and Financing of the Acquisition 23. The former holders of Target shares received the Merger Consideration as soon as practicable after the Closing Date. As required by the Merger Agreement, prior to the First Effective Time, XXXXXXXXXX, on behalf of Merger Sub1, caused to be deposited, XXXXXXXXXX, in trust for the benefit of holders of Target shares, the Merger Consideration, XXXXXXXXXX sufficient to pay the aggregate Cash Consideration and evidence of XXXXXXXXXX Common Shares in book-entry form representing the number of XXXXXXXXXX Common Shares sufficient to deliver the aggregate Share Consideration. 24. ... Upon the issuance of the XXXXXXXXXX Common Shares as the aggregate Share Consideration as described in Paragraph 33.ii, XXXXXXXXXX, added to the stated capital account maintained for such common shares an amount equal to the aggregate FMV of the Share Consideration. ...
Technical Interpretation - Internal
1 September 2015 Internal T.I. 2015-0605491I7 - In-kind transfer of property from an RRSP to an IPP
Other Considerations The advantage rules do not appear to have any application to the specific type of transfer that you raise in your letter (i.e. a transfer of property from an RRSP to an IPP in accordance with paragraph 146(16)(a)), but could conceivably apply in other situations where individuals effect transactions between their RRSP and an IPP. ...
Technical Interpretation - Internal
13 September 2001 Internal T.I. 2001-0083067 - HEALTH AND WELFARE TRUSTS
Other Considerations A) The determination of whether a benefit is received by an employee-shareholder in his/her capacity as an employee or as a shareholder involves a finding of fact. ...
Technical Interpretation - Internal
24 January 2001 Internal T.I. 2000-0059517 - DISPOSITION OF PARTNERSHIP AT DEATH
Canadian Resource Property Considerations First of all, it has been the long-standing view of the Department/Agency that an interest in a partnership, the underlying property of which is a Canadian resource property (as defined in subsection 66(15) of the Act), is not a Canadian resource property itself (1). ...
Technical Interpretation - External
28 April 1995 External T.I. 9501085 - TRANSFER OF RRSP FUNDS TO CHARITY ISSUED ANNUITY
Other Considerations: In addition to the rules respecting qualified investments for RRSP's, certain registration requirements will affect the manner in which the annuity purchase is handled. ...