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2024 Ruling 2022-0948081R3 - Loss Consolidation Arrangement

The following transactions will occur on or before XXXXXXXXXX to unwind each loss consolidation arrangement between the Losscos and the Profitcos: (a) The Losscos will contribute capital to the Newcos, in cash, equal to the amount of the accrued and unpaid dividends on the Newco Preferred Shares; (b) Using the capital received from the Losscos, the Newcos will pay, in cash, the balance of the accrued and unpaid dividends on the Newco Preferred Shares to their respective Profitcos; (c) Each respective Profitco will pay in cash to the Losscos all accrued and unpaid interest in respect of the relevant Lossco Loans; (d) The Losscos will repay each of the Newco Loans by assigning the Lossco Loans to the respective Newcos in full satisfaction of the principal amounts due under the respective Newco Loans; (e) Newcos will redeem the Newco Preferred Shares held by the respective Profitcos in consideration for a non-interest bearing demand promissory note issued by the respective Newcos (the "Newco Notes"). ... The Newco Preferred Shares will not at any time during the implementation of the Proposed Transactions be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 42. ...

5 July 1996 GST/HST Interpretation 11690-9 - Proposed Amendment to Section 153 - The "Trade-in Approach"

The amount of the reduction is equal to the value of the consideration for the trade-in. ... This will occur where the value of the consideration for the trade-in is equal to, or greater than, the value of the consideration for the supply of tangible personal property made by the supplier. ... The consideration assigned to the individual's traded in book is $15.00. ...

28 September 2011 GST/HST Interpretation 135932 - GST/HST Interpretation - [...] [Supplies of design, construction, financing and management services of a facility]

To the extent that any consideration become payable before January 1, 2008, the GST at 6% applies to that consideration. ... Subsection 168(2) provides that, notwithstanding subsection 168(1), where consideration for a taxable supply becomes due on more than one day, tax is payable on the day any part of the consideration becomes due and is based on the consideration that becomes due on that day. As the consideration for the construction of the [facility] was not paid by Hospital Authority at any time before consideration for the supply became due, it must be determined when consideration for the supply became due. ...

26 February 2001 GST/HST Interpretation 33311/HQR0001582 - — Eligibility to Claim ITC

If the consideration for the Services was included in the total consideration paid, the ITCs claimed would be for inputs to an exempt supply, as the sale of Accounts was a financial service and no GST was charged or remitted on the supply. ... The Registrant states that the supply of the Services is made for no consideration, and there is no consideration directly linked to this supply in contracts: therefore any claim under either of these subsections for ITCs related this supply must fail. ... The specified purpose for which XXXXX receives consideration is the sale of the Accounts. ...

6 September 1995 GST/HST Interpretation 1995-09-06 - Application of GST to Coins Denominated in U.S. Currency Which are Collected by the ("the Town") in its Coin-operated Parking Meters

This should not be confused with the actual consideration given for a supply. Although in many supplies the amount of consideration given and the value of consideration are the same, there will be instances where the two amounts are different. In such instances it is the value of consideration which is the base on which tax is calculated and not the amount of consideration actually given. ...

3 July 2002 GST/HST Interpretation 34735 - Sale of Real Property to

" Pursuant to subsection 153(1), the "value of the consideration is... deemed to be equal to (a) where the consideration... is expressed in money, the amount of the money; and (b) where the consideration... is other than money, the fair market value of the consideration at the time the supply is made. ... This corresponds to the concept of "valuable consideration" at common law (A frequently cited definition of "consideration" at common law is from Lush J. in Currie v. ... " In the present situation, then, the tax on the consideration paid by the Association in XXXXX is subject to tax in that year, notwithstanding that the consideration is, in part, for the supply of the long-term lease made in XXXXX (the remainder being consideration for the Interim Lease). ...

28 July 2006 GST/HST Ruling 81356 - GST Rate Change on Purchase of Hotel Rooms

With respect to determining when consideration becomes due, subsection 152(1) provides that the consideration, or a part thereof, for a taxable supply shall be deemed to become due on the earliest of (a) the earlier of the day the supplier first issues an invoice in respect of the supply for that consideration or part and the date of that invoice, (b) the day the supplier would have, but for an undue delay, issued an invoice in respect of the supply for that consideration or part, and (c) the day the recipient is required to pay that consideration or part to the supplier pursuant to an agreement in writing. ... Therefore, pursuant to paragraph 152(1)(c), the consideration for the supply is deemed to become due on the day the purchaser is required to pay that consideration or part to the Company pursuant to the Agreement. As a result, and pursuant to subsection 168(2), the purchaser is required to pay GST/HST on the supply of the memorialization merchandise on the earlier of the day he/she pays the consideration or part and the day he/she is required to pay the consideration or part under the Agreement. ...

2004 Ruling 2004-0099651R3 - Migration to Canada / PUC Reduction

The licensing arrangement will be for a period of XXXXXXXXXX years, and S3Co will pay to ACo as consideration, a lump-sum amount. ...

15 April 2008 Internal T.I. 2008-0266251I7 - Liechtenstein foundation

The rulings, which follow the OECD's August 16, 1999, report on the application of the OECD model tax treaty to partnerships, reverse positions previously taken by the Ministry of Finance, which used to take only one feature into consideration- the separate legal personality of the foreign entity. ...

5 October 2007 APFF Roundtable, 2007-0242441C6 F - Gains ou pertes sur taux de change

With respect to the capital payment, the capital gain or loss should be calculated by taking into consideration the above-mentioned position. ...

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