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Where an assignment agreement is entered into on or after May 7, 2022, and the assignment agreement indicates in writing that a part of the consideration is attributable to the reimbursement of a deposit paid by the assignor to the builder under the purchase and sale agreement, the proposed amendment excludes the amount attributable to the deposit from the consideration for a taxable assignment sale. ...

GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022-- summary under Subsection 254(4) Summary Under Tax Topics- Excise Tax Act- Section 254- Subsection 254(4) Purchaser who purchases after receiving a taxable assignment of the purchase contract from the builder may wish to file the housing rebate application directly (p. 4 under Q.4) After noting that the amount of the rebate is based on the total consideration for the taxable supply of the house, including any consideration paid by an assignee for a taxable assignment sale of an agreement to purchase the house from the builder, CRA stated: Only one new housing rebate application can be made for each new house. ...

CRA responded: Notwithstanding the actual payer, [s. 182] deems the recipient of the supply to have paid and the supplier to have collected GST/HST on that deemed consideration at the time the amount is paid. Therefore, Aco would be deemed to have collected the GST/HST on the deemed consideration for the cancellation compensation and Bco would be deemed to have paid the GST/HST. ...

The administrative arrangement continues to apply where a dentist or dental corporation follows the terms of the arrangement: the dentist identified the two separate supplies, for example, the invoice issued to the patient identifies the consideration for the supply of the orthodontic appliance or artificial tooth separately from the consideration for the supply of the dental service, and the ITC claim relates to mixed-use purchases (to make both taxable and exempt supplies) such as overhead and general operating expenses and certain direct expenses or inputs (for example, personal property such as arch wires used exclusively to fabricate orthodontic appliances). ...

The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. ...

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024-- summary under Section 11.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part II- Section 11.1 Administrative arrangement with the Canadian Dental Association Under the CRA arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances and claim input tax credits (ITC) accordingly – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

As noted below, this apportionment is based on the extent to which the property or service is used to make taxable supplies for consideration (which in this context does not include nominal consideration).... 34. ...

Under s. 168, the GST collectible under a lease depends on the time at which the consideration under the lease is paid or becomes payable. ... Part #1 After noting that the “determination as to whether the balance of the lease term following the upfront payment consists of only one lease interval or multiple lease intervals will depend on whether a ‘periodic charge’ made subsequent to the upfront payment is recognized as consideration for the lease of the home for GST/HST purposes,” CRA stated: [I]f during a particular lease interval, the intent of the Long-Term Lessee is to use the home for the purpose of its continuous occupancy as a place of residence for a month or longer, that supply would be an exempt supply and the landlord would not have to collect tax on that supply. But, if during the next lease interval, the Long-Term Lessee intends to use the home to make short-term rentals, the lease of the home by the landlord to the Long-Term Lessee for the particular lease interval would be a taxable supply and, if a registrant, the landlord would have to collect tax on that supply calculated on the consideration for that supply (that is, on the particular periodic charge). ...

Qualifying revenue means the inflow of cash, receivables, or other consideration arising in the course of the ordinary activities of the eligible employer in Canada in a particular period. ... (b) Not typical of the normal activities or risks inherent in the normal operations of the entity Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. (c) Primarily out of the control of owners or management Consideration should be given to the extent that inflows are influenced by the decision of owners or management.... ...