Search - consideration
Results 8811 - 8820 of 13642 for consideration
Ruling
2021 Ruling 2021-0889011R3 - Redemption of MFT units held by registered plans
As consideration for the units being redeemed, the Trust will assign an equivalent number of its USco shares to Buyco. 23. ...
Ruling
2023 Ruling 2023-0964601R3 - Loss consolidation arrangement
The Losscos Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be: a. subject of any undertaking that is referred to subsection 112(2.2) as a “guarantee agreement”; b. the subject of a “dividend rental arrangement” as contemplated in subsection 112(2.3); 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); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 30. ...
Technical Interpretation - Internal
31 July 2023 Internal T.I. 2021-0876331I7 - SR&ED ITC Recapture Rules
(footnote 6) Accordingly, in the situation presented, while a question of fact and law, it appears that the trees would be considered the particular property that has been acquired from a person or a partnership (paragraph 127(27)(a) of the Act) or acquired from a transferor (subsection 127(32) of the Act) since the taxpayer will receive property from the province in exchange for the payment of consideration (i.e., the stumpage fees) in accordance with the terms of the timber sales contract entered into between the parties. ...
Technical Interpretation - External
27 June 2024 External T.I. 2023-1000391E5 - BC Secondary Suite Incentive Program
In the situation under consideration, it is our view that either subsection 13(7.1) or paragraph 53(2)(k) will generally apply to reduce the cost of the property, such that any amount that would otherwise be required to be included in a Homeowner’s income because of paragraph 12(1)(x) will be reduced by means of subparagraph 12(1)(x)(vi). ...
Ruling
2023 Ruling 2023-0970321R3 - Loss consolidation arrangement
The shares on which a dividend is declared or paid in the course of the Proposed Transactions, will not, at any time be: i. the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; ii. the subject of a dividend rental arrangement as that term is defined in subsection 248(1); iii. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or iv. issued for consideration that includes: a. 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 b. any right of the type described in subparagraph 112(2.4)(b)(ii). 28. ...
Ruling
2022 Ruling 2022-0924291R3 - Loss Consolidation Arrangement
The Subscribed 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). 30. ...
Old website (cra-arc.gc.ca)
Supply of Photocopies
The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the charity. 3. ... The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the public institution. 4. ... The consideration is based on a cost per photocopy. 1. The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the public institution 4. ...
Current CRA website
Supply of Photocopies
The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the charity. 3. ... The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the public institution. 4. ... The consideration is based on a cost per photocopy. 1. The consideration paid by the customer for the supply of photocopies exceeds the direct cost (as defined in subsection 123(1) of the ETA) to the public institution 4. ...
GST/HST Interpretation
27 July 2009 GST/HST Interpretation 108225 - Application of GST/HST to Supplies of Dutiable Spirits
Interpretation Given GST is calculated on the consideration for a supply in accordance with section 154 of the ETA. ... GST payable is calculated on the value of the consideration, excluding duty. ... GST payable is calculated on the value of the consideration, including duty. ...
GST/HST Interpretation
16 January 1995 GST/HST Interpretation 11585-1, 11755-1, 11783-2 - Business Office Incentive
Technical Information Bulletin B-042 sets out four criteria which the payment must meet to qualify as a deferred price adjustment: 1) the payment must be a reduction in consideration which occurs at some point in time after the GST has been charged or collected; 2) the payment must be given to the original purchaser of the supply; 3) the payment must be a reduction in consideration which relates to the original supply; and 4) the payment may be made for any reason, but must not depend upon any action undertaken, or supply made, by the recipient. ... It is also our view that the incentive represents consideration for the supply by the vehicle purchaser of agreeing to borrow from the XXXXX specified by XXXXX. ... The incentive is consideration for that supply, therefore the incentive cannot also be the price reduction described above. ...