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Administrative Policy summary

Brian Darling, "Revenue Canada Perspectives" in Income Tax and Goods and Services Tax Considerations in Corporate Financing, 1992 Corporate Management Tax Conference Report (Canadian Tax Foundation, 1993), 5 -- summary under Subsection 5907(6)

Brian Darling, "Revenue Canada Perspectives" in Income Tax and Goods and Services Tax Considerations in Corporate Financing, 1992 Corporate Management Tax Conference Report (Canadian Tax Foundation, 1993), 5-- summary under Subsection 5907(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(6) 1-20, question 7, at 5:13: [w]hat is reasonable in the circumstances can be determined on a case-by-case basis. ...
Administrative Policy summary

Bulletin LTT 10-2000 Transactions for Nominal Consideration November 2000 -- summary under Subsection 3(1)

Bulletin LTT 10-2000 Transactions for Nominal Consideration November 2000-- summary under Subsection 3(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Section 3- Subsection 3(1) Partitioning of a Co-tenancy Where a partitioning of land takes place and each or any of the "co-tenants" receives land equal in value to their original interest in the whole parcel, no tax will be payable. ...
Administrative Policy summary

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023 -- summary under Section 175.1

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Section 175.1 Summary Under Tax Topics- Excise Tax Act- Section 175.1 Michael, a GST/HST-registered sales person, uses his car to meet clients. ...
Administrative Policy summary

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023 -- summary under Section 272

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Section 272 Summary Under Tax Topics- Excise Tax Act- Section 272 Parent a continuation of wound-up subsidiary for s. 156(2) purposes 60. ...
Administrative Policy summary

P-222 - "Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act (the "ETA")", 10 December 1998 -- summary under Section 159

P-222- "Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act (the "ETA")", 10 December 1998-- summary under Section 159 Summary Under Tax Topics- Excise Tax Act- Section 159 To convert from foreign currency into Canadian currency for purposes of Part IX of the Excise Tax Act, a person may only use the rate of exchange from: the source used for an actual conversion (i.e. foreign currency is exchanged for Canadian dollars); the source the person typically uses for actual conversions; a Canadian chartered bank; the Bank of Canada; or the rate provided by the Customs Branch of the Department for purposes of converting the value for duty of imported goods. ...
Administrative Policy summary

Excise and GST/HST News – No. 96 under "University and public college meal plans" June 2015 -- summary under Section 13

Excise and GST/HST News – No. 96 under "University and public college meal plans" June 2015-- summary under Section 13 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part III- Section 13 assimilation of supply to agreement Single consideration Where a student enters into an agreement for meals to be provided under a meal plan and the agreement specifies that there is a single consideration, but the payment for that consideration may be made on an instalment basis, the CRA accepts that this type of arrangement meets the requirement of "single consideration". Top-ups In addition, the CRA considers "top-ups", or the addition of funds to a qualifying meal plan, to be additional consideration for the same supply for GST/HST purposes. ...
Administrative Policy summary

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)" -- summary under Paragraph A(b)

Examples- Qualifying consideration- Part A Example 1 A non-resident FI has its head office outside Canada and a branch in Canada. ... Therefore the amount is included in Part A of qualifying consideration.... ... Any amount in respect of capital cost allowance that is permitted as a deduction for purposes of the ITA and that is with respect to a Canadian activity is included in Part A of qualifying consideration ...
Administrative Policy summary

GST Memorandum 300-7 "Value of Supply" under "Non-Arm's Length Supplies" -- summary under Subsection 153(2)

GST Memorandum 300-7 "Value of Supply" under "Non-Arm's Length Supplies"-- summary under Subsection 153(2) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(2) Applies where single consideration shown/relative FMV may be used Combined Consideration 12. Pursuant to subsection 153(2), where consideration is paid for a supply and other consideration is paid for one or more other supplies or matters (either in the form of a single amount on an invoice or separate amounts on an invoice), and the consideration for one of the supplies or matters exceeds the consideration that would be reasonable if the other supply or matter were not provided, the following rule applies: the consideration for each of the supplies and matters is deemed to be that part of the total of all amounts, each of which is consideration for one of those supplies or matters, that may reasonably be attributed to each of those supplies and matters. 13. ...
Administrative Policy summary

GST/HST Memorandum 12.2 [aka 12-2] "Refund, Adjustment, or Credit of the GST/HST under Section 232 of the Excise Tax Act" April 2008 -- summary under Subsection 232(2)

A reduction in consideration may occur under the following circumstances: when some or all of the consideration is returned; as a result of surpassing a certain volume of purchases, i.e., a volume rebate; where goods delivered are found to be substandard; or where goods are returned to the supplier for a full or partial refund of the consideration. 7. The reduction in consideration must be given to the original recipient of the supply, or that person's agent, and must relate to an amount that has been collected or charged. 8. The reduction in consideration must also relate to the original supply and may be made for any reason but must not depend on any action undertaken by the recipient or any supply made by the recipient.... 12. ...
Administrative Policy summary

GST/HST Technical Information Bulletin B-032 “Expenses Related to Pension Plans” 17 November 2015 -- summary under Recipient

GST/HST Technical Information Bulletin B-032 “Expenses Related to Pension Plans” 17 November 2015-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient Employer incurring consideration for third-party supplier of pension plan services 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. … [T]he employer is entitled to claim an ITC in respect of the tax payable to the investment manager to the extent the investment management service is acquired for supply to the plan trust in the course of the employer’s commercial activities, provided that all of the conditions of section 169… are met. ...

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