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Total consideration Items to include or exclude from total consideration 6. ... Items to include or exclude from total consideration are discussed in Section 19.3.1, Rebate For Builder-Built Unit (Land Purchased). ... Rebate s 254.1 Calculating the Rebate (Building Purchased/Land Leased) where the rebate does not form part of value of consideration for the building: Fair market value of land, building, and related structures: $374,500 or less Rebate Calculation: 2.34% of the total consideration for the building and related structures to a maximum of $8,750 Example Footnote 4 Assume that total consideration for the building and related structures is $90,000. ...

Total consideration Items to include or exclude from total consideration 6. ... Items to include or exclude from total consideration are discussed in Section 19.3.1, Rebate For Builder-Built Unit (Land Purchased). ... Rebate s 254.1 Calculating the Rebate (Building Purchased/Land Leased) where the rebate does not form part of value of consideration for the building: Fair market value of land, building, and related structures: $374,500 or less Rebate Calculation: 2.34% of the total consideration for the building and related structures to a maximum of $8,750 Example Footnote 4 Assume that total consideration for the building and related structures is $90,000. ...

Table of contents 1.0 Purpose 2.0 Overview 3.0 Expenditures and recapture – Quick reference 4.0 Legislation – Conditions to apply the recapture rules 4.1 Conditions under which a claimant will report a recapture 4.2 A recapture in respect of a transfer of qualified expenditures under subsection 127(13) 5.0 Definitions 5.1 Cost 5.2 Property 5.3 Corporeal and incorporeal property 5.3.1 Example – Acquisition of intellectual property 5.4 Disposition 5.5 Proceeds of disposition 6.0 No recapture 6.1 No recapture on salaries or overhead 6.1.1 Example – No recapture on salaries or overhead 6.2 De minimis rule 6.2.1 Example – No recapture on scrap sales / de minimis rule 6.3 Non-arm's length disposition of equipment 7.0 Factors affecting the SR&ED investment tax credit recapture 7.1 Purchase of SR&ED components 7.1.1 Example – Purchase of SR&ED components 7.2 Items in inventory 7.2.1 Example – Items in inventory 7.3 All or substantially all equipment for SR&ED purposes 7.4 Conversion to commercial use 7.5 Disposition or conversion to commercial use of "another property that incorporates the property" 7.6 Property acquired through a contract involving SR&ED and other work 8.0 SR&ED investment tax credit recapture rules – Corporations and individuals 8.1 Calculation of a recapture amount – Corporations and individuals 8.2 Effect of recapture – Corporations and individuals 8.3 The SR&ED investment tax credit rate of recapture – Corporations and individuals 9.0 Recapture on transferred qualified expenditures 9.1 Calculation of recapture amount on transferred qualified expenditures 9.2 Timing considerations 9.2.1 Example – Timing considerations 10.0 Partnerships 10.1 Calculation of a recapture amount – Partnerships 10.2 Effect of recapture – Partnerships 11.0 Recycled materials 12.0 Forms 13.0 Examples 13.1 Calculation of a recapture amount for a corporation or individual using the proceeds of disposition amount 13.2 Calculation of a recapture amount for a corporation or individual using the fair market value amount 13.3 Determining the notional UCC to estimate the fair market value of a capital property 13.4 Calculation of recapture on transferred qualified expenditures where only a portion of the qualified expenditures were transferred 13.5 Calculation of recapture on transferred qualified expenditures where all of the qualified expenditures were transferred 13.6 Calculation of recapture on transferred qualified expenditures where only a portion of the qualified expenditures were transferred 13.7 Calculation of a recapture amount for a corporation or individual on conversion to commercial use when the fair market value is less than the qualified expenditure in respect of the property Appendix A – References A.1 Legislative references Appendix B – Revisions B.1 Explanation of changes 1.0 Purpose The purpose of this document is to clarify the position of the Canada Revenue Agency (CRA) regarding the recapture of scientific research and experimental development (SR&ED) investment tax credits (ITCs) when administering the SR&ED legislation under the federal Income Tax Act and the Income Tax Regulations. 2.0 Overview At the outset of an SR&ED project, a performer may not know whether the materials used in the project will be consumed or transformed, or whether the project will result in a product that has some value to the performer or someone else. ... Legislative references Income Tax Act Subsection 127(13) Agreement to transfer qualified expenditures Subsection 127(29) Recapture of investment tax credit of allocating taxpayer 9.2 Timing considerations If the performer and the payer have different tax year-ends, timing problems may arise for the purposes of the ITC recapture rules. ... Legislative references Income Tax Act Subsection 127(13) Agreement to transfer qualified expenditures Subsection 127(29) Recapture of investment tax credit of allocating taxpayer 9.2.1 Example – Timing considerations Corporation A (the payer) enters into a contract with Corporation B (the performer) to do SR&ED on its behalf. ...

Any taxpayer may apply for APA consideration, regardless of the size of the organization, the type or scope of its operations, or the nature of the transactions and proposed TPMs. 5. ... You should propose an initial term for an APA, giving appropriate consideration to the industry and transactions involved. ... We may arrange a post-settlement meeting with you to discuss terms of settlement, renewal considerations, the timeliness of the process, and any problems encountered during the process. ...

Any taxpayer may apply for APA consideration, regardless of the size of the organization, the type or scope of its operations, or the nature of the transactions and proposed TPMs. 5. ... You should propose an initial term for an APA, giving appropriate consideration to the industry and transactions involved. ... We may arrange a post-settlement meeting with you to discuss terms of settlement, renewal considerations, the timeliness of the process, and any problems encountered during the process. ...

Consideration 5. For GST/HST purposes, consideration is defined in subsection 123(1) to include “any amount that is payable for a supply by operation of law.” 6. ... For more information on the value of consideration for a supply, refer to Memorandum 300-7 Value of Supply. ... Under section 161, where tangible personal property or services are supplied and the amount of consideration for the supply shown in the invoice in respect of the supply may be reduced if the amount is paid within a time specified in the invoice, or an additional amount is charged to the recipient by the supplier if the amount of the consideration is not paid within a reasonable period specified in the invoice, the consideration due shall be deemed to be the amount of consideration shown in the invoice. ...

Meaning of consideration Subsection 123(1) provides that consideration includes any amount that is payable for a supply by operation of law. For the purposes of section 141.02, consideration does not include nominal consideration. ... Example 6 Bank Z purchases office paper for making taxable supplies for consideration and for making exempt supplies. ...

Where the consideration for a supply, or a portion thereof, is other than money, the value of that consideration is equal to the fair market value of the consideration at the time the supply was made. ... Combined consideration ss 153(2) 55. Where two or more supplies are made for a combined consideration, the total consideration must be attributed reasonably to each supply. ... A deposit is not treated as consideration paid for a supply until the supplier applies the deposit as consideration for the supply. ...

Where the consideration for a supply, or a portion thereof, is other than money, the value of that consideration is equal to the fair market value of the consideration at the time the supply was made. ... Combined consideration ss 153(2) 55. Where two or more supplies are made for a combined consideration, the total consideration must be attributed reasonably to each supply. ... A deposit is not treated as consideration paid for a supply until the supplier applies the deposit as consideration for the supply. ...

A builder would still be able to use either the floor space method or the consideration method at the time of filing the rebate. ... Consideration method Under this method, the estimated RST/PST content in the new housing is equal to 2% of the total consideration paid for the housing (i.e., the total amount paid to purchase the housing before any HST is applied and before any new housing rebate is taken into account). ... The individual may choose either the consideration method or the floor space method to calculate the rebate amount. ...