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9 January 2001 GST/HST Ruling 25986 - Application of the GST/HST to the Supply of Funding for Research and Development of Effective Training Materials

Rulings Requested 1) The funding provided by the Funder to the Society is consideration for a taxable supply. ... As the funding is not consideration for a supply, it will not be subject to the GST/HST. ... As indicated above, this funding is not consideration for supplies made by the Society. ...

2017 Ruling 2017-0699201R3 - Cross-border Butterfly

Predecessor Parent acquired all of the issued and outstanding shares of Predecessor Subsidiary from an Arm’s-Length person for FMV cash consideration (approximately $XXXXXXXXXX) in XXXXXXXXXX. ... As consideration for the DC Transfer 1, Newco: (a) assumed DC’s liabilities that related to the Canadian Transferred Businesses; (b) issued a promissory note (Newco Debt) to DC, the amount of which (approximately $XXXXXXXXXX) corresponded to a portion of the DC Debt 1 that was approximately equivalent to the proportion that the aggregate FMV at that time of the Canadian Transferred Businesses was of the aggregate FMV at that time of the Canadian Transferred Businesses and the Canadian Retained Businesses, and the interest rate on which is one basis point higher than the interest rate on the corresponding DC Debt 1; and (c) issued additional Newco Common Shares to DC, having an aggregate FMV at that time equal to the amount by which the aggregate FMV at that time of the Canadian Transferred Businesses so transferred to Newco, exceeded the total amount of DC’s liabilities assumed by Newco and the Newco Debt issued by Newco to DC, as described in Paragraph 23(a) and (b), respectively. ... As consideration for the Distribution Property, TCo will: (a) with respect to the DC Receivable, assume (TCo Assumed Liability 1) a portion of the DC Debt 1, which portion will be equal to the outstanding Principal Amount of the DC Receivable; and (b) with respect to the Newco Common Shares and the DC Cash Transfer (if that transfer is required to be made): (i) assume (TCo Assumed Liability 2) a portion of the DC Current Liabilities (if required), and (ii) issue TCo Preferred Shares to DC having an aggregate FMV at that time equal to the amount by which the aggregate FMV of the Newco Common Shares transferred by DC to TCo at that time and the DC Cash Transfer (if that transfer is required to be made), exceeds the TCo Assumed Liability 2 (if any is required to be assumed), as described in Paragraph 41(b)(i). ...

Deemed dispostions

In certain circumstances, the Income Tax Act considers that a property has been disposed of, even though no real compensation in the form of money or other consideration has been received. ... In this guide, "sale" generally refers to a transaction where the ownership of property is transferred from one person or entity to another for a sum of money or other consideration. In the case of a deemed disposition, ownership of the property is not transferred for money or other consideration. ...

Deemed dispositions

In certain circumstances, the Income Tax Act considers that a property has been disposed of, even though no real compensation in the form of money or other consideration has been received. Some examples of when a deemed disposition may occur are: transfers of property to a trust gifts of property (that is, the name of the beneficial owner of the property is changed) the owner dies the owner ceases to be a resident of Canada In this guide, "sale" generally refers to a transaction where the ownership of property is transferred from one person or entity to another for a sum of money or other consideration. In the case of a deemed disposition, ownership of the property is not transferred for money or other consideration. ...

12 July 2023 GST/HST Ruling 174441 - and GST/HST INTERPRETATION - Application of GST/HST on funds raised through crowdfunding

What is the consideration used to determine the GST/HST to be remitted? ... Is the GST/HST calculated on a tax extra or tax included basis on the consideration? ... As per section 165, GST/HST is calculated on the value of the consideration for the supply. ...

23 April 1997 GST/HST Interpretation HQR0000571 - Snow Removal and GST

The owner/operators and clubs have not charged nor has XXXXX paid GST with respect to the consideration paid by XXXXX for the snow ploughing services. 8. ... GST does not have to be paid on the consideration for a snow-ploughing service provided by a person who is not and is not required to be registered for GST purposes at the time when the consideration becomes payable or is paid without having become payable. ... The supplier has disclosed the consideration and the GST in respect of the supply to the recipient as required under subsection 223(1)[,] 4. ...

17 December 2003 GST/HST Interpretation 40164 - and APPLICATION RULING Rebate in Respect of the Purchase of Qualifying Motor Vehicles

In your letter, you put forth the position that the amount eligible for rebate should include the full consideration price paid less the value of the engine. ... However, the consideration that should be included in the certified amount of the purchase price is the consideration that can reasonably be attributed to the special feature or the adaptation. In this case, the amount that can reasonably be attributed to the special feature or the adaptation is limited to the consideration for the increase in door dimensions. ...

22 January 1995 GST/HST Interpretation 1995-01-22 - GST Treatment of Activities and Projects Undertaken by a Non-Profit Organization

Pursuant to subsection 153(1), the value of the consideration for a supply shall be deemed to be equal to: (a) where the consideration or that part is expressed in money, the amount of the money, and (b) where the consideration or that part is other than money, the fair market value of the consideration or that part at the time the supply was made. ... It is evident that this consideration is primarily for a service of television advertising. ... Section 218 imposes GST on the value of consideration for an imported taxable supply. ...

Meaning of the Phrase a Particular Class or Kind as Found in subsection 153(3) of the Act

The value of the consideration for the supply made by one person is the fair market value of property received from the other person. ... Under this subsection, where: a) the consideration or a part of the consideration for a supply of property of a particular class or kind is property of that class or kind, b) both the supplier and the recipient are registrants, and c) the property is acquired by the recipient and the consideration or that part thereof is acquired by the supplier as inventory for use exclusively in commercial activities of the recipient or supplier, as the case may be, the value of the consideration or that part thereof shall be deemed to be nil. ... Hence, the value of consideration for the supply by each of Co. A and Co. ...

P-221 Meaning of the phrase "a particular class or kind" as found in subsection 153(3) of the Act

The value of the consideration for the supply made by one person is the fair market value of property received from the other person. ... Under this subsection, where: a) the consideration or a part of the consideration for a supply of property of a particular class or kind is property of that class or kind, b) both the supplier and the recipient are registrants, and c) the property is acquired by the recipient and the consideration or that part thereof is acquired by the supplier as inventory for use exclusively in commercial activities of the recipient or supplier, as the case may be, the value of the consideration or that part thereof shall be deemed to be nil. ... Hence, the value of consideration for the supply by each of Co. A and Co. ...

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