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GST/HST Interpretation

3 November 1999 GST/HST Interpretation HQR0001930 - - ITCs & Pension Plan Expenses

Under subsection 123(1) of the ETA the recipient of a supply is defined as the person who is liable to pay consideration under the agreement for the supply. ... There is no re-supply to the trust in this instance and since the value of the consideration has been set by a non-related third party section 155 is not an issue. ... Under s[ubs]ection 123(1) the recipient of a supply is defined as the person liable to pay the consideration i.e., the invoice is made out in their name. ...
GST/HST Interpretation

13 August 1999 GST/HST Interpretation HQR0001909 - Coin-operated Amusement Machines

Interpretation Requested You have asked us to clarify whether subsection 165.1(2) of the ETA can apply to a supply made by an amusement machine that can be altered, either by re-programming the machine or by resetting internal switches in the machine, to offer supplies for consideration exceeding twenty-five cents. ... For example, subsection 165.1(2) would apply to a supply made through an amusement machine that is programmed or set to only offer a single game for a total consideration of twenty-five cents even if that machine is capable of being re-programmed or reset to offer a single game for fifty cents. However, subsection 165.1(2) would not apply to any supplies made through that amusement machine while the machine is programmed or set to offer a supply for consideration exceeding twenty-five cents. ...
GST/HST Interpretation

31 March 2000 GST/HST Interpretation 8120/HQR0001726 - Gift Certificates

In the first transaction, the NPO is paying a discounted amount (consideration of XXXXX per certificate) to XXXXX for the XXXXX "gift certificate". The certificate therefore no longer satisfies one of the conditions specified under Policy Paper P-202 Gift Certificates, which states that the consideration given for the gift certificate must equal the stated value on the "certificate". ... The sale of a gift certificate is not a taxable supply, therefore no GST payable on the consideration paid for the gift certificate. ...
Old website (cra-arc.gc.ca)

Canadian Views/Attitudes Towards the Sharing of Tax Information - Quantitative Phase

Moreover, public opinion continues to be influenced by various considerations that potentially could be used by the CRA as rationales for such sharing of information. Support for information sharing rose notably when exposed to these considerations. ... Indeed, there are many considerations related to information sharing that are acceptable to Canadians. ...
Archived CRA website

ARCHIVED - Meaning of private health services plan [1988 and subsequent taxation years]

On the other hand, an amount paid by an employee as a premium, contribution or other consideration to a private health services plan qualifies as a medical expense for purposes of the medical expense tax credit by virtue of paragraph 118.2(2)(q). ... If the agreed consideration is in the form of cash premiums, they usually relate closely to the coverage provided by the plan and are based on computations involving actuarial or similar studies. ... The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. 8. ...
Old website (cra-arc.gc.ca)

Expenses Related to Pension Plans

An expense, including a pension-related expense, is incurred by an employer where the employer is liable to pay consideration to a third party supplier under an agreement for a supply. ... The employer is liable to pay the consideration under the agreement with the investment manager and is the recipient of the taxable supply. ... Since the pension-related expense incurred by the employer (i.e., the person liable to pay the consideration under the agreement for the supply) has been paid for out of the pension plan trust assets, the payment by the plan trust is consideration for a taxable supply of an investment management service made by the employer to the plan trust. ...
Scraped 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 Ruling

15 January 2015 GST/HST Ruling 151911R - – […][Application of the GST/HST to the Sale of Real Property]

Your client received consideration from the neighbouring farmer for the lease of the Property, which you stated was to protect against a potential claim of adverse possession. ... There was no written lease agreement in place. o From [yyyy] to [yyyy], the rental arrangement continued with the same farmer and for the same annual consideration of $[….]. The parties entered into a written lease agreement. o From [yyyy] to [mm/yyyy], the rental arrangement continued with the same farmer but for an annual consideration of $[…]. ...
GST/HST Interpretation

8 June 2020 GST/HST Interpretation 201085 - – Application of GST/HST and excise duties on supplies of spirits and wine

INTERPRETATION GST/HST is imposed on taxable supplies made in Canada, calculated at the applicable rate, on the value of the consideration paid or payable for the supply, except where the supply is a zero-rated supply or specifically exempt. ... For this purpose, “consideration” is defined for GST/HST purposes to include “…any amount that is payable for a supply by operation of law”. ... Further, since the products are not specifically exempt or zero-rated under the ETA, GST/HST would be calculated on the value of the consideration at the applicable rate. ...
GST/HST Ruling

21 July 2014 GST/HST Ruling 142194 - Application of the GST/HST to the supply of certain engineering reports

RULING GIVEN Based on the facts set out above, we rule that payments made to the Engineer in respect of the Agreement, including the Royalty Agreement are consideration for a taxable supply made by the Engineer and that section 162 does not apply in respect of the supply. ... EXPLANATION Generally, every recipient of a taxable supply made in Canada shall pay GST/HST calculated on the value of the consideration for the supply. ... Payments made to the Engineer in respect of the Agreement, including the Royalty Agreement, are consideration for a taxable supply of the engineering study in respect of a specific site relating to the evaluation of the site and its potential for the generation of hydroelectric power. ...

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