Search - consideration

The debt will be a capital loss in the following situations: You acquired it to earn income from a business or property You acquired it as consideration or payment for the sale of capital property in an arm's length transaction In most cases, the capital loss is equal to the adjusted cost base of the debt. ...

A discounter (within the meaning of the Tax Rebate Discounting Act) who pays an amount to a person to acquire from the person a right to a refund of tax (within the meaning of the Tax Rebate Discounting Act), notwithstanding section 139 Footnote 1, is deemed to have made two supplies: (a) a taxable supply of a service for consideration equal to the lesser of: (i) 2/3 × (refund- amount paid to the person by the discounter); and (ii) $30; and (b) a separate exempt supply of a financial service. ... As a result, the consideration for the taxable supply equals 2/3 of the difference between the actual tax refund and the amount paid by the discounter to the client, to a maximum of $30. The remainder of the fee (or discount) charged by the discounter to the client is treated as consideration for the financial service. ...

An "improvement" in respect of capital property is defined in section 123(1) of the Act as any property or service to the extent that the consideration for the property or service would be included in determining the adjusted cost base of the capital property for income tax purposes. Where the capital property in question is a residential complex, the improvement must relate to a property or service the consideration for which is included in the adjusted cost base of the residential complex. ... Other property and services that are supplied in respect of the land, interest, building or appurtenance that form part of the single unit residential complex may also be eligible for rebate as an improvement provided the consideration paid or payable for such property or service would be included in determining the adjusted cost base of the complex for income tax purposes. ...

In order to take advantage of the capital gains deduction under subsection 110.6(2.1) of the Act before the shares cease to be qualified small business corporation shares, the individual sells the shares to a related corporation in consideration for shares and elects an amount under subsection 85(1) of the Act that will permit the individual to take the maximum capital gains deduction. ... Interpretation Section 84.1 of the Act describes the circumstances in which consideration received by a taxpayer on a sale of shares to a corporation should be accounted for as a dividend. ... Interpretation The shares of the subsidiaries issued in consideration for the property comprising businesses A and B are deemed by section 54.2 of the Act to be capital property of Canco. ...

The aeroplane, 35 hours of dual flight time and 30 hours of solo flight time are provided by the vocational school for a single consideration. ... Scenario No.2: The vocational school provides the 35 hours of dual flight time, 30 hours of solo flight time, 90 hours of build-up time, ground school instruction and the use of an aeroplane for the purposes of completing the flight time, for a single consideration. ... Scenario No. 3: The vocational school provides the solo flight time, dual flight time and ground school instruction for a single consideration. ...

An "improvement" in respect of capital property is defined in section 123(1) of the Act as any property or service to the extent that the consideration for the property or service would be included in determining the adjusted cost base of the capital property for income tax purposes. Where the capital property in question is a residential complex, the improvement must relate to a property or service the consideration for which is included in the adjusted cost base of the residential complex. ... Other property and services that are supplied in respect of the land, interest, building or appurtenance that form part of the single unit residential complex may also be eligible for rebate as an improvement provided the consideration paid or payable for such property or service would be included in determining the adjusted cost base of the complex for income tax purposes. ...

Pursuant to paragraph 183(1)(b), that supply is deemed to have been made for no consideration. ...

GST/HST Policy Statement P-164 Date of Issue February 15, 1994 Subject Rent-to-own agreements Legislative Reference(s) The following provisions of the Excise Tax Act may apply: 123(1) Definition of "sale"; 133 Agreement as supply; 152(2) Consideration under leases; 168(5) Sale of real property; 168(6) Combined supply; 191(1) & (3) Self-supply of residential real property; 191(2) Self-supply on termination of purchase and sale agreement; 254 GST New Housing Rebate; 336 Transitional provisions National Coding System File Number(s) 11870-5 Effective Date January 1, 1991 Text This policy statement will discuss the transfer of possession of a newly constructed or substantially renovated residential complex from a builder to a recipient under a lease, licence or similar arrangement before transfer of ownership of the complex to the recipient. ... If the sale is taxable, the recipient will generally be required to pay GST on the value of the consideration for the sale at the earlier of the transfer of possession and the transfer of ownership of the property. ... GST will be payable on the value of consideration at Jan. 1, 1993, however, the GST New Housing Rebate will not be available before the transfer of title. ...

Where the excess land does not qualify as part of the residential complex, the self-supply rules relating to a residential complex would not apply to that portion of the excess land and any part of the GST paid on the consideration for the supply of a residential building and land that relates to such excess land would not be eligible for the housing rebates. ... The allocation must be based on a method that is fair and reasonable (for example, the fair market value of each of the properties) and consideration must be given to any restrictions and/or severance laws or regulations, in effect on the date of acquisition, of any part of the property, including the portion that does not qualify as the residential complex. ... The allocation of the consideration payable for the residential complex (including the qualifying land) and the non-qualifying land should be determined on a fair and reasonable basis. ...

In order to take advantage of the capital gains deduction under subsection 110.6(2.1) of the Act before the shares cease to be qualified small business corporation shares, the individual sells the shares to a related corporation in consideration for shares and elects an amount under subsection 85(1) of the Act that will permit the individual to take the maximum capital gains deduction. ... Interpretation Section 84.1 of the Act describes the circumstances in which consideration received by a taxpayer on a sale of shares to a corporation should be accounted for as a dividend. ... Interpretation The shares of the subsidiaries issued in consideration for the property comprising businesses A and B are deemed by section 54.2 of the Act to be capital property of Canco. ...