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Results 651 - 660 of 1664 for consideration
Current CRA website
General anti-avoidance rule (GAAR)
Transactions – Scenario 1 Individual holds high ACB Class B shares on which the capital gains exemption was previously crystallized Subco transfers Property A to Holdco in consideration for Class B shares of Holdco As a result, the PUC of the Class B shares is increased across all Class B shares Before: Image description The before image shows the situation before entering the series of transactions. ... After: Image description The after image shows the result of the transaction in which Subco transferred Property A to Holdco in consideration for Class B shares of Holdco. ... Transactions – Scenario 2 Canco redeems the preferred shares held by the individual, triggering a deemed dividend of $849,999 and an equivalent capital loss which is added to the ACB of the common shares under subsection 40(3.6) Individual transfers their common shares to Holdco in consideration of preferred shares with an ACB and redemption value equivalent to the $850,000 and nominal value common shares Holdco redeems the preferred shares without any tax consequences Before: Image description The before image depicts the following: The individual holds common shares and preferred shares of Canco. ...
Current CRA website
Platform-based short-term accommodation
An accommodation platform operator in respect of a supply of short-term accommodation made through an accommodation platform, generally means a person (other than the supplier or an excluded operator in respect of the supply) that controls or sets the essential elements of the transaction between the supplier and the recipient; and if the above does not apply to any person, then it is a person who is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier. In relation to a supply of property, an excluded operator is a person who: does not set, directly or indirectly, any of the terms and conditions under which the supply is made, is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply, and is not involved, directly or indirectly, in the ordering or delivery of the property; or solely provides for the listing or advertising of the property or service or for the redirecting or transferring to a digital platform on which the property is offered; or is solely a payment processor. ...
Current CRA website
Supply of qualifying goods in Canada
A distribution platform operator in respect of the supply of qualifying goods made through a specified distribution platform is a person other than the supplier or an excluded operator who: controls or sets the essential elements of the transaction between the supplier and the recipient, or if that circumstance does not apply to any person, is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier. In relation to the supply of qualifying goods, an excluded operator is a person who: does not set, directly or indirectly, any of the terms and conditions under which the supply is made, is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply, and is not involved, directly or indirectly, in the ordering or delivery of the property; or solely provides for the listing or advertising of the property or for the redirecting or transferring to a digital platform on which the property is offered; or is solely a payment processor. ...
Current CRA website
Pacific Association of Tax Administrators (PATA) Transfer Pricing Documentation Package
The extent of the use of CCA property by associated enterprises which are not CCA participants, including the amounts of consideration paid or payable by these non-participants for use of the CCA property. ... For the taxpayer and the comparable, identify the factors taken into account by the taxpayer to evaluate comparability, including the characteristics of the property or service transferred, the functions performed (and the significance of those functions in terms of their frequency, nature and value to the respective parties), the assets employed (taking into consideration their age, market value, location, etc.), the risks assumed (including risks such as market risk, financial risk, and credit risk), the terms and conditions of the contract, the business strategies pursued, the economic circumstances (for example, the geographic location, market size, competitive environment, availability of substitute goods and services, levels of supply and demand, nature and extent of government regulations, and costs of production, etc.), and any other special circumstances. Criteria used in the selection of comparables including database screens and economic considerations. ...
Current CRA website
LTN1 Registration under the Select Luxury Items Tax Act
Registered vendor of subject vehicles A person is required to register as a registered vendor of subject vehicles if, in the course of a business of selling subject vehicles in Canada, the person either: sells a subject vehicle that has never been registered with the Government of Canada or a province Footnote 2 and the consideration for the sale, the retail value determined under section 16 at the time the sale is completed or the manufacturer's suggested retail price (MSRP) is above the $100,000 price threshold imports a subject vehicle that has never been registered with the Government of Canada or a province Footnote 3 and the taxable amount of the import determined under section 20, the retail value at the time of importation or the MSRP is above the $100,000 price threshold Registered vendor of subject aircraft A person is required to register as a registered vendor of subject aircraft if, in the course of a business of selling subject aircraft in Canada, the person either: sells a subject aircraft that has never been registered with the Government of Canada Footnote 1 and the consideration for the sale, the retail value determined under section 16 at the time the sale is completed or the MSRP is above the $100,000 price threshold imports a subject aircraft that has never been registered with the Government of Canada Footnote 1 and the taxable amount of the import determined under section 20, the retail value at the time of importation or the MSRP is above the $100,000 price threshold Registered vendor of subject vessels A person is required to register as a registered vendor of subject vessels if, in the course of a business of selling subject vessels in Canada, the person either: sells a subject vessel that has never been registered with the Government of Canada Footnote 1 and the consideration for the sale, the retail value determined under section 16 at the time the sale is completed or the MSRP is above the $250,000 price threshold imports a subject vessel that has never been registered with the Government of Canada Footnote 1 and the taxable amount of the import determined under section 20, the retail value at the time of importation or the MSRP is above the $250,000 price threshold Applying for registration A person that is required to apply to register as a registered vendor of a type of subject item under the Act must apply to register with the CRA by the earlier of: the day the sale is completed, where a sale first triggers the requirement to register the day the subject item is accounted for in accordance with section 32 of the Customs Act, where an importation first triggers the requirement to register To apply for registration, a person must either use Business Registration Online or complete Form L500, Luxury Tax Registration Application, and submit it to the CRA. ...
Current CRA website
Program history - from VRP to FCTIP
The rebate will continue to be available in respect of a supply of a tour package or accommodation made on or before March 22, 2017, regardless of when the consideration for the supply is paid or the tour takes place. ...
Current CRA website
Contract registration
Unless a DTC election is made, amounts that are left in the plan (after taking into consideration any repayments under the Canada Disability Savings Act) are to be paid to the beneficiary or the beneficiary's estate. ...
Current CRA website
Organization of the Agency
Rating Scale Board’s Assessment and Related Comments Next Steps Strong STRONG Consideration should be given to assessing the effectiveness of horizontal management throughout the Agency. ...
Current CRA website
Filing Form TD1, Personal Tax Credits Return
Individuals paid by commissions and who claim expenses can elect to use Form TD1X, Statement of Commission Income and Expenses for Payroll Tax Deductions, to take into consideration the expenses in the calculation of their income tax. ...
Current CRA website
Summary of the Corporate Business Plan 2016-2017 to 2018-2019
Our updated Agency Workforce Plan takes into consideration the plans and priorities outlined in this document, and will help make sure we maintain and build a knowledgeable workforce with the agility needed to meet current and future requirements. ...