Search - consideration

The XXXXX fee is consideration for a supply of a service in respect of an application for a development permit and is exempt pursuant to paragraph 20(c) of Part VI of Schedule V. ... The payment is not consideration for the supply of a right to use real property of the Town as suggested in the incoming memorandum. ... The transfer of the land or money to the municipality is consideration for the supply by the municipality of a right or permit to develop the land. ...

The XXXXX fee is consideration for a supply of a service in respect of an application for a development permit and is exempt pursuant to paragraph 20(c) of Part VI of Schedule V. ... The payment is not consideration for the supply of a right to use real property of the Town as suggested in the incoming memorandum. ... The transfer of the land or money to the municipality is consideration for the supply by the municipality of a right or permit to develop the land. ...

Interpretation Requested In your letter, you asked whether a supplier of taxable services to XXXXX has to refund the GST collected on the supply where the consideration for the supply has been reduced. ... The amount refunded would be that portion of the tax calculated on the amount by which the consideration for the supply was reduced. ... This is because XXXXX would have recorded, to the RAA, the tax paid on the supply of the service prior to the reduction in the consideration. ...

In consideration of the Assumption of the Bridge Liability by XXXXX agreed to transfer lands to XXXXX to meet the XXXXX needs in connection with the reparation of the Bridges and related work. ... XXXXX was also granted, for nominal consideration, easements for some other properties connected with the Bridges (parcels of lands, structural elements of the Bridges, etc.). ... XXXXX agrees with XXXXX that the consideration to be shown in each of the conveyances from XXXXX in respect of XXXXX[.] ...

You would like to know whether or not the U.S. income should be included as part of the total consideration for taxable supplies when you make the determination as to whether or not your client exceeds the small supplier threshold. Interpretation Given In determining whether or not a person is a small supplier, a person must include the total consideration for taxable supplies both inside and outside Canada (i.e., including those that are zero-rated under Schedule VI to the Excise Tax Act (ETA) and excluding financial services, supplies by way of sale of capital property of the person or associate, and consideration attributable to the sale of goodwill of a business). ... In Canada, performers are normally considered to be self-employed and their income is included as part of the total consideration for taxable supplies when they are determining whether or not they are small suppliers. ...

The Department has generally taken the position that payments made by a commercial organization have a purchase purpose and are consideration for a supply. ... Where the grantor is a commercial organization, therefore, the transfer payment will normally be regarded as consideration." ... Therefore, the payment appears to have a purchase purpose and be consideration for a supply. ...

Section 17 of Part VI of Schedule V to the ETA exempts "a supply of a membership in a public sector body (other than a membership in a club the main purpose of which is to provide dining, recreational or sporting facilities or in a registered party) where each member does not receive a benefit by reason of the membership, other than (a) an indirect benefit that is intended to accrue to all members collectively, (b) the right to receive services supplied by the body that are in the nature of investigating, conciliating or settling complaints or disputes involving members, (c) the right to vote at or participate in meetings, (d) the right to receive or acquire property or services supplied to the member for consideration that is not part of the consideration for the membership and that is equal to the fair market value of the property or services at the time the supply is made, (e) the right to receive a discount on the value of the consideration for a supply to be made by the body where the total value of all such discounts to which a member is entitled by reason of the membership is insignificant in relation to the consideration for the membership, or (f) the right to receive periodic newsletters, reports or publications (i) the value of which is insignificant in relation to the consideration for the membership, or (ii) that provide information on the activities of the body or its financial status, other than newsletters, reports or publications the value of which is significant in relation to the consideration for the membership and for which a fee is ordinarily charged by the body to nonmembers, except where the body has made an election under this section in prescribed form containing prescribed information. ...

XXXXX would treat the funds received as a result of the rebate claim as additional consideration paid by XXXXX for the Building. ... Specifically, is the consideration to be paid by XXXXX "nominal", and as a result can paragraph 141.01(2)(b) of the Excise Tax Act (the "Act") be applied to deem the inputs acquired by XXXXX in constructing the Building to have been acquired for use otherwise than in the course of its commercial activities on the basis that these inputs are acquired for the purposes of making supplies that are "not taxable supplies made for consideration"? ... Our Comments: (i) ITC Claims: It is our view that the consideration (as outlined above) to be paid by XXXXX for the Building is not nominal. ...

Subsection 231(1) of the Act states that, where a person has made a taxable supply for consideration and, has remitted the tax, and at a later time determines that the consideration and tax have become, in whole or in part, a bad debt, the person may deduct an amount equal to the tax fraction of the bad debt written off in the books of account. ... Any consideration included for financing the purchase, such as interest, would have to be removed before the tax fraction is applied. Therefore, where a bad debt includes consideration for more than one supply, and one or more of the supplies is exempt, the person claiming the bad debt deduction is required to remove that portion of the consideration relating to the exempt supply before determining the tax content of the bad debt. ...

The amount of the discount will reduce the value of the consideration for each of the goods purchased. ... Where a customer of XXXXX purchases property and redeems points, the value of the consideration is reduced by the amount of the reduction associated with the points. ... Where a maximum dollar amount is deducted, that amount would have to be prorated among each of the items purchased based upon the value of the consideration for each item. ...