Search - consideration

The interposition of WHA does not, by some alchemy, transmute the discharge of the insurer's obligation to the insured into the consideration for a service provided to the reinsurer's agent. ...

In finding that the VAT paid on the agent's fee qualified for deduction as input tax in respect of the supply to the developer of services, Lord Hope indicated (at p. 6) that the matter was to be looked at from the standpoint of the person who is claiming the deduction by way of input tax and, that the relevant question was: "Was something being done for him for which, in the course of furtherance of the business carried on by him, he has had to pay a consideration which has attracted VAT? ...

The funds are ultimately derived as consideration for the employee’s services, and on that basis they are properly to be considered emoluments or earnings. ...

ARQ, 2016 QCCS 2158, aff'd 2016 QCCA 1303-- summary under Subsection 240(1.1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1.1) Uber drivers, as operators of “taxi” businesses, likely were required to register for QST The ARQ obtained a search warrant for searching an Uber Canada office in Montreal, which under s. 40 of the Tax Administration Act (Quebec), required that the ARQ employee laying the information have reasonable grounds to believe that Uber Canada was committing an offence, on the grounds that (1) Uber Canada (which was registered for QST purposes) was making false returns by not treating the per-drive commissions of 20% which it earned from its Quebec drivers as being consideration for taxable supplies, and (2) it was aiding the drivers in committing the offence of wilfully evading the collection of QST by virtue of its system for collecting the customer fares (through the customers’ credit cards) not treating those fares as being subject to QST (or GST). ...

The evidence demonstrates that the sale subject to the assessment was justified on the basis of personal and family considerations of Mr. ...

Stock ‘94 Szolgáltató Zrt. v Regional Customs and Finance Directorate-General for Southern Transdanubia of the National Tax and Customs Office, Hungary, [2016] BVC 45, C-208/15 (European Court of Justice (5th Chamber))-- summary under Paragraph (f) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (f) interest on a loan funding a taxable supply of goods was part of the consideration for a single supply of the goods Stock ‘94 was a company which acted as an “integrator,” i.e., it assisted Hungarian farmers (“integrated producers”) by making a loan to the farmer, which was used to purchase current assets for use on the farm. ...

The parties returned with a revised plan of arrangement which had essentially the same proposed terms, except that contingent cash consideration to be paid to the InterOil shareholders based on the subsequently-measured size of InterOil’s natural gas resource was capped once the assessed size reach 11 trillion cubic feet equivalent rather than 10 tcfe. ...

In remitting TD’s request for a one-day extension to the Commissioner for reconsideration, and in applying Stemijon, he stated (at paras. 55, 59): While it was open to the Commissioner to have regard to Ministry of Finance policy statements, she erred in treating them as the only relevant consideration. ...

Under the agreement between JDI and IPPL, JDI accomplished its servicing of the equipment under its “services agreement” with IPPL by means of delegating to IPPL the performance of such services as its agent, in consideration for fees going in the opposite direction. ...

This requires consideration of whether the Sample Documents are, or record, communications made for the dominant purpose of giving or receiving legal advice. ...