Search - consideration

It is issued or sold for consideration by the supplier of the property or service or another party for use at a particular supplier. The consideration paid for the certificate may not necessarily be the same as the monetary exchange value. It is accepted as payment or partial payment of the consideration for a supply of property or a service offered by the supplier of that property or service. ...

9 February 2017 Ruling 181234-- summary under Paragraph 154(2)(b) Summary Under Tax Topics- Excise Tax Act- Section 154- Subsection 154(2)- Paragraph 154(2)(b) Alberta carbon levy included in consideration subject to GST Does the GST apply to the Alberta carbon levy required to be collected on the sale of natural gas by a natural gas distributor (the “Distributor”) to its customers.” ... As the carbon levy is imposed in respect of the supply of natural gas, is payable by [the Distributor]’s customers as recipients (for purposes of the ETA) of the supply of natural gas, is collectible by [the Distributor] as the supplier (for purposes of the ETA) of the supply of natural gas, and is not a prescribed provincial levy for purposes of section 154 of the ETA, the consideration for the supply of natural gas made by [the Distributor] will include the carbon levy. As the supply of natural gas made by a gas distributor in Alberta to its customers in Alberta is a taxable supply, the consideration payable for this supply (which includes the carbon levy) is subject to the GST. ...

21 December 2016 Ruling 157873-- summary under Paragraph (d) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (d) fee charged on assigning a receivable was part of the exempt consideration for the sale An automobile dealer (the “Dealer”) enters into contracts with customers, which could be conditional sales contracts, instalment sales contracts, credit agreements or finance contracts with instalments, and assigns each contract to a lender, so that the lender receives an assignment of all amounts then due and over time. ... In connection with ruling that the assignment is a financial supply under (d) of financial service and the fee part of the (exempt) consideration therefor, CRA stated: [E]ach… Contract…[is] a “debt security”… as each one represents a right to be paid money. ... The Fee received by the Dealer…under the Contracts… forms part of the consideration received for the exempt supply, that is the assignment of the Contract…. ...

28 February 2019 CBA Roundtable, Q.15-- summary under Paragraph 272.1(3)(b) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(3)- Paragraph 272.1(3)(b) FMV of services rendered may differ from the consideration Does CRA have a definition of “management or administrative service” that it applies for purposes of s. 272.1(8) (other than the inclusion of an “asset management service” as defined in s. 123(1))? If the consideration paid for such a service is based on an industry standard of say X%, would that constitute the fair market value (FMV), even if between related parties? ... This could include, for example, organizing, monitoring, planning and coordinating the activities of the partnership, making decisions and directing resources to assist the partnership in achieving its defined objectives, as well as maintaining records, and preparing reports. … (b) … The CRA recognizes that there are various methods that may be used and the appropriateness of any valuation methodology used in a particular case is a matter of valuation principles and practice. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. ...

1996 Corporate Management Tax Conference Round Table, Q. 7-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) Until it completes its review, RC will permit excess debt to be assumed by the transferee corporation in consideration for the issuance by it of a note payable or in consideration for the redemption by it of some of the shares issued to acquire the transferred assets. ...

19 December 2003 Headquarters Letter Case No. 45870-- summary under Paragraph 142(1)(c) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(1)- Paragraph 142(1)(c) Charges for electrical capacity, if regarded as consideration for a supply separate from a supply of electricity, would represent consideration for intangible personal property (rather than tangible personal property as would be the case for a supply of electricity) and, therefore, would not be eligible for zero-rating, and would be governed by s. 142(1)(c) rather than (a). ...

Furthermore, 'reimbursement' means consideration paid to the supplier by the recipient, equal to the value of the consideration paid by the supplier to a third party on behalf of the recipient. ...

The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest but only to the extent such consideration is not paid for the actual use of the underlying property. ...

23 December 2002 Technical Interpretation RITS 38588-- summary under Subsection 153(1) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(1) tenant property taxes part of consideration "Where a separate amount is paid by a lessee on account of property taxes, this amount is part of the consideration for the rental of the property, even if the lessee pays the amount directly to the municipality... ...

27 March 2000 HQ Letter RITS No. 7940-- summary under Taxable Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Taxable Supply Where an individual who sells the shares of a company to an unrelated third party also receives consideration for a non-compete covenant, the non-compete payment would be considered to be consideration for a supply made by the individual, but would not qualify as a taxable supply because the individual would not be engaged in commercial activity. ...