Search - consideration

This information circular provides general guidelines on some of the relevant considerations in the exercise of this discretion. ... Given the complexity of transfer pricing issues, applications relating to transfer pricing matters will be referred to the Transfer Pricing Review Committee for their consideration under subsection 220(3.1). ... If it is discovered during the course of the review that the taxpayer had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 27. ...

Footnote 5 For example, the applicant organization must be able to show that particular sport activities are chosen with the charitable purposes and public benefit as primary considerations. ... A determination of whether an organization's purpose is charitable will be made by taking into account the following considerations: the proportion of the organization's expenditures related to activities open to all levels of skill relative to the expenditures related to elite competitive sport activities the number of people participating in activities open to all levels of skill relative to the number of people participating in elite competitive sport activities the amount of financial support for elite competitive athletes and the relative amount of resources allocated to them in excess of the basic or average amount of resources allocated to other participants whether the organization presents itself as primarily providing activities open to everyone served by the charity's programs, regardless of their level of ability, and conducts outreach to recruit participants regardless of level of skill 5. ... To do so, it will have to show that the limitation to the particular sport: is reasonable, as opposed to arbitrary, considering the nature of the recognized charitable purpose it intends to further Footnote 25 will not deter or exclude a substantial proportion of those that could be served by the charity is the most practical use of the charity's resources, at least as a starting point, for reasons such as expertise, effectiveness, and financial consideration Organizations that meet the criteria for registration outlined in this policy can apply for charitable status by going to Apply to become a registered charity. ...

This memorandum provides general guidelines on some of the relevant considerations in the exercise of this discretion. ... If it is discovered during the course of the review that the registrant had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 65. ... If a registrant’s VDP application is accepted under Category 3 (the Limited Program), in consideration of the relief being provided, the registrant will be required to waive their rights to object and appeal in relation to the specific matter disclosed in the VDP application and any specifically related assessment of taxes. ...

A person's threshold amount for any fiscal year is calculated by reference to the total value of the consideration for taxable supplies (other than supplies of financial services, sales of capital property and zero-rated exports) made by that person (and any associates) in the immediately preceding fiscal year. ... Time during consideration not counted ss 310(2) 47. The time during which a question is being determined by the Tax Court of Canada is excluded from the limitation periods for issuing assessments and the filing of Notices of Objection and Appeal. ... Time during consideration not counted ss 311(7) 52. The time between the day an application is served on a person as described in paragraph 48 and the day the determination becomes final in the case of a named person (or the day the person is notified of not being named in an order of the court, in any other case) is excluded from the limitation periods for the issuing of assessments and the filing of Notices of Objection and Appeal. ...

Any amount to which the trustee is entitled for acting as a trustee of the trust that is included in computing the trustee's income under the ITA, or where the trustee is an individual, the individual's business income, is deemed to be consideration for the supply of that service. ... The consideration for the supply is deemed to be equal to the amount determined under the ITA to be the proceeds of disposition of the property. ... The consideration for the deemed supply of the property is deemed to be equal to the amount determined under the ITA to be the proceeds of disposition of the property. ...

In such cases, consideration may be given to waiving penalties and/or interest in whole or in part for the period beginning on the first payment due date under the payment arrangement until the amounts owing are paid, provided the agreed payments are made on time. 14. Consideration would not generally be given to cancelling penalties based on an inability to pay or financial hardship unless an extraordinary circumstance has prevented compliance. ... For example, when a business is experiencing extreme financial difficulty, and enforcement of such penalties would jeopardize the continuity of its operations, the jobs of the employees and the welfare of the community, consideration may be given to providing relief of the penalties. ...

The core charge forms part of the consideration payable for the new part. ... Where the non-registrant supplies the used part to the vendor at the time the new automotive part is purchased, the GST/HST trade-in rules apply and the GST/HST is calculated on the difference between the consideration payable, including the core charge, for the new part being sold and the amount credited for the trade-in. ... The vendor is required to collect GST/HST on the total consideration payable for the new part, including the core charge. ...

A "recipient" is defined, in part, as the person who is liable to pay the consideration in respect of a supply. ... Generally, for the insured to be considered the recipient of the supply related to repairing or replacing the property, the invoice must name the insured as the purchaser and the insured must be the person legally liable to the supplier for payment of the consideration for the supply. ... GST/HST forms E412- Notice of Revocation of Waiver GST59- GST/HST Return for Imported Taxable Supplies and Qualifying Consideration GST62- Goods and Services Tax/Harmonized Sales Tax (GST/HST) Return (Non-personalized) GST66- Application for GST/HST Public Service Bodies' Rebate and GST Self-government Refund GST74- Election and Revocation of an Election to use the Quick Method of Accounting GST111- Financial Institution GST/HST Annual Information Return GST190- GST/HST New Housing Rebate Application for Houses Purchased from a Builder GST287- Election or Revocation of the Election by Public Service Bodies to Use the Special Quick Method of Accounting GST303- Application to Offset Taxes by Refunds or Rebates RC79- Deposit Advice RC199- Voluntary Disclosures Program (VDP)- Taxpayer Agreement RC7066-SCH- Provincial Schedule- GST/HST Public Service Bodies' Rebate GST/HST guides RC4027- Doing Business in Canada- GST/HST Information for Non-Residents RC4028- GST/HST New Housing Rebate RC4419- Financial Institution GST/HST Annual Information Return GST/HST info sheets GI-066- How a Charity Calculates the Net Tax to be Reported on its GST/HST Return (revised) GI-067- Basic GST/HST Guidelines for Charities (revised) GI-068- Basic GST/HST Guidelines for Public Institutions (revised) GI-106- Ontario First Nations Point-of-Sale Relief- Reporting Requirements for GST/HST Registrant Suppliers (revised) GI-118- Builders and GST/HST NETFILE GI-119- Harmonized Sales Tax – New Place of Supply Rule for Sales of Specified Motor Vehicles GI-120- Assignment of a Purchase and Sale Agreement for a New House or Condominium Unit GI-121- Determining Whether a Public Service Body is Resident in a Province for Purposes of the Public Service Bodies' Rebate GST/HST memoranda 17-14- Election for Exempt Supplies GST/HST technical information bulletins B-102- First Nations Goods and Services Tax- Place of Supply (revised) Excise duty notices EDN30- Tobacco Marking Requirements under the Amended Stamping and Marking of Tobacco Products Regulations Softwood lumber products export charge notices SWLN39- Termination of the 10% Additional Export Charge and Refund of Overpayments SWLN40- Surge Charge – Alberta Region (June 2011) All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at www.cra.gc.ca/gsthsttech, at www.cra.gc.ca/etsl, and at www.cra.gc.ca/exciseduty. ...

As a GST/HST registrant, you are generally eligible to claim ITCs to recover the GST/HST paid or payable by you on taxable property and services to the extent that you acquired them for consumption, use or supply for the purpose of making taxable supplies for consideration (for example, taxable supplies of commercial ride-sharing services for which an amount is charged) where all other conditions for claiming an ITC are met. ... An ITC cannot be claimed for the GST/HST paid or payable on property or services which you acquired for purposes other than making taxable supplies for consideration (for example, for personal use). If you acquire an input for the purpose of making taxable supplies for consideration and for other purposes, you are required to allocate the use of the input between these purposes in order to claim an ITC on the input. ...

For a grandparented residential condominium unit or condominium complex, the transitional tax adjustment would not be based on the degree of completion of the unit or complex and is instead calculated at 4.5% of the consideration payable for the unit or complex. ... Appendix C – Summary tables The following tables illustrate the proposed transitional rules for purchases of newly constructed or substantially renovated residential complexes from a builder, taking into consideration the previous two rate reductions in the GST. ... Purchase and sale agreement entered into after November 8, 2012 Ownership transferred Possession transferred Rate of tax 2006 transitional rebate 2008 transitional rebate GST new housing rebate Footnote 1 PST transitional rebate Before April 1, 2013 Before April 1, 2013 5% No No Yes No Before April 1, 2013 After March 31, 2013 5% No No Yes No After March 31, 2013 Before April 1, 2013 5% No No Yes No After March 31, 2013 After March 31, 2013 14% No No Yes Yes Footnote 2 Purchase and sale agreement entered into after October 30, 2007 and before November 9, 2012 Ownership transferred Possession transferred Rate of tax 2006 transitional rebate 2008 transitional rebate GST new housing rebate Footnote 3 PST transitional rebate After December 31, 2007 and before April 1, 2013 After December 31, 2007 and before April 1, 2013 5% No No Yes No After December 31, 2007 and before April 1, 2013 After March 31, 2013 5% No No Yes No After March 31, 2013 After December 31, 2007 and before April 1, 2013 5% No No Yes No After March 31, 2013 After March 31, 2013 5% No No Yes No Purchase and sale agreement entered into after May 2, 2006 and before October 31, 2007 Ownership transferred Possession transferred Rate of tax 2006 transitional rebate 2008 transitional rebate Footnote 4 GST new housing rebate Footnote 5 PST transitional rebate After December 31, 2007 and before April 1, 2013 After December 31, 2007 and before April 1, 2013 6% No Yes Yes No After December 31, 2007 and before April 1, 2013 After March 31, 2013 6% No Yes Yes No After March 31, 2013 After December 31, 2007 and before April 1, 2013 6% No Yes Yes No After March 31, 2013 After March 31, 2013 6% No Yes Yes No Purchase and sale agreement entered into before May 3, 2006 Ownership transferred Possession transferred Rate of tax 2006 transitional rebate Footnote 6 2008 transitional rebate Footnote 7 GST new housing rebate Footnote 8 PST transitional rebate After June 30, 2006 and before April 1, 2013 After June 30, 2006 and before April 1, 2013 7% Yes Yes Yes No After June 30, 2006 and before April 1, 2013 After March 31, 2013 7% Yes Yes Yes No After March 31, 2013 After June 30, 2006 and before April 1, 2013 7% Yes Yes Yes No After March 31, 2013 After March 31, 2013 7% Yes Yes Yes No Footnotes Footnote 1 The GST new housing rebate is available if all of the conditions for claiming the rebate are met, for example, the total consideration payable for the housing is less than $450,000. ...