Search - consideration

Many factors must be taken into consideration in establishing whether an individual is an employee or is self-employed. ... In applying this factor, external influences such as economic conditions, changes in the public mood, etc., which may affect the sale of artistic or literary works will be taken into consideration, and (l) the nature of the literary works undertaken by a writer. ... The restrictions in section 67.1 on the amount that may be deducted for food or beverages consumption expenses (i.e., generally, 50% of such expenses-see the current version of IT-518, Food, Beverages and Entertainment Expenses) and the restrictions on motor vehicle expenses (see the current version of IT-521, Motor Vehicle Expenses Claimed by Self-Employed Individuals) must be taken into consideration in determining such travel expenses. ¶ 9. ...

However, this subparagraph will only apply if the taxpayer settles or extinguishes all debt obligations for consideration that does not include any unit, interest, share, or debt obligation of: (a) the taxpayer; (b) any person with whom the taxpayer does not deal at arm's length; or (c) any partnership or trust of which the taxpayer or a person described in (b) above is a member or beneficiary. ... Subsection 18(9.1) deals with the deductibility of fees paid to a person or partnership to reduce the interest rate on a debt obligation, or as penalties or bonuses in consideration for the repayment of all or a portion of a debt obligation prior to its maturity. ... However, subsection 18(9.1) does not apply to any fee, penalty, or bonus that: may reasonably be considered to have been paid for the extension of the term of a debt obligation or as consideration for the substitution or the conversion of a debt obligation into another debt obligation or into a share; is contingent or dependent upon the use of, or production from, property; is computed by reference to revenue, profit cash flow, commodity price, or any similar criterion; or is computed by reference to any dividends paid or payable on any class of shares in a corporation. ...

In the future, consideration may be given to expanding the scope of the program to include individuals who prepare other types of tax returns such as income tax returns for trusts (Form T3, Trust Income Tax and Information Return), and GST/HST returns. ... Consideration is being given to publishing a list of registered tax preparers. ... While they have been designed in consideration of the needs of third parties and are available to tax preparers, they have not been designed to exclusively address the needs of tax preparers. ...

Many factors must be taken into consideration in establishing whether an individual is an employee or is self-employed. ... In applying this factor, external influences such as economic conditions, changes in the public mood, etc., which may affect the sale of artistic or literary works will be taken into consideration, and (l) the nature of the literary works undertaken by a writer. ... The restrictions in section 67.1 on the amount that may be deducted for food or beverages consumption expenses (i.e., generally, 50% of such expenses-see the current version of IT-518, Food, Beverages and Entertainment Expenses) and the restrictions on motor vehicle expenses (see the current version of IT-521, Motor Vehicle Expenses Claimed by Self-Employed Individuals) must be taken into consideration in determining such travel expenses. ¶ 9. ...

Many factors must be taken into consideration in establishing whether an individual is an employee or is self-employed. ... In applying this factor, external influences such as economic conditions, changes in the public mood, etc., which may affect the sale of artistic or literary works will be taken into consideration, and (l) the nature of the literary works undertaken by a writer. ... The restrictions in section 67.1 on the amount that may be deducted for food or beverages consumption expenses (i.e., generally, 50% of such expenses-see the current version of IT-518, Food, Beverages and Entertainment Expenses) and the restrictions on motor vehicle expenses (see the current version of IT-521, Motor Vehicle Expenses Claimed by Self-Employed Individuals) must be taken into consideration in determining such travel expenses. ¶ 9. ...

However, this subparagraph will only apply if the taxpayer settles or extinguishes all debt obligations for consideration that does not include any unit, interest, share, or debt obligation of: (a) the taxpayer; (b) any person with whom the taxpayer does not deal at arm's length; or (c) any partnership or trust of which the taxpayer or a person described in (b) above is a member or beneficiary. ... Subsection 18(9.1) deals with the deductibility of fees paid to a person or partnership to reduce the interest rate on a debt obligation, or as penalties or bonuses in consideration for the repayment of all or a portion of a debt obligation prior to its maturity. ... However, subsection 18(9.1) does not apply to any fee, penalty, or bonus that: may reasonably be considered to have been paid for the extension of the term of a debt obligation or as consideration for the substitution or the conversion of a debt obligation into another debt obligation or into a share; is contingent or dependent upon the use of, or production from, property; is computed by reference to revenue, profit cash flow, commodity price, or any similar criterion; or is computed by reference to any dividends paid or payable on any class of shares in a corporation. ...

A bonus or premium paid by a mortgagor to a mortgagee in consideration for the mortgagee's consent to an early redemption of the mortgage is considered to constitute an amount paid to a creditor on account or in lieu of payment of any debt and consequently this premium or bonus cannot qualify as an "eligible capital expenditure"; (d) amounts paid or payable by a corporation to a person in his or her capacity as a shareholder. ... Where goodwill, as a recognizable asset, is acquired by the purchaser of a business in the circumstances described in ¶ 6, the consideration given for the goodwill, as well as any legal and accounting fees that can be directly associated with the purchase of the goodwill, will qualify as an eligible capital expenditure. If the portion of the total consideration for the business that is allocated to the goodwill is unreasonable, or if the goodwill has a value which the vendor and purchaser have not specified, the Canada Revenue Agency (CRA) can apply the provisions of section 68 to deem what may reasonably be regarded as the amount for the goodwill. ...

Election to not account for GST/HST on actual taxable supplies Effective for supplies made after March 21, 2013, the budget proposes to allow a participating employer of a pension plan and a pension entity of the pension plan to make a joint election to treat an actual taxable supply of property or a service by the employer to the pension entity as being made for no consideration where the employer accounts for and remits tax on the deemed supply of the property or service or on the consumption or use of inputs for the purpose of making the actual supply. ... Relief from accounting for tax on deemed taxable supplies Effective for fiscal years of an employer beginning after March 21, 2013, the budget also proposes that: A participating employer of a pension plan would be fully relieved from applying the deemed taxable supply rules in respect of the pension plan for a fiscal year where: an election with a pension entity of the pension plan to treat actual taxable supplies as being made for no consideration (discussed above) is not in effect for the employer; and the amount of the GST (including the federal part of the HST) that the employer was (or would have been, but for this measure) required to account for and remit under the deemed supply rules in respect of the pension plan in its preceding fiscal year is both less than $5,000 and less than 10% of the total net GST (including the federal part of the HST) paid by all pension entities of that pension plan in that preceding fiscal year. ... An employer that is entitled to relief under this provision would also be able to treat its actual taxable supplies as being for no consideration where the election, discussed above, is in effect. ...

The set on-call fee that is paid in respect of this on-call coverage would be consideration for this taxable supply. Additional amounts paid to compensate the medical practitioner for their intervention in patient care would generally be viewed as consideration for an exempt supply, as that intervention would generally qualify as an exempt supply of a health care service under section 5 of Part II of Schedule V. ... It should also be noted that if the consideration for the supply of the right to call upon the medical practitioner is payable or reimbursed by the government of a province, under a plan established under an act of the legislature of the province to provide for health care services for all insured persons of the province, the supply of the right may be an exempt supply of property under section 9 of Part II of Schedule V. ...

(c) The dividends are calculated as a fixed amount or by reference to a fixed percentage of the fair market value of the consideration for which the shares were issued. ... (e) The shares cannot be redeemed, cancelled or acquired for more than the fair market value of the consideration for which the shares were issued plus any unpaid dividends on such shares. ... Since a share that is issued as a stock dividend is issued for no consideration, it cannot qualify as a share of a specified class because it cannot satisfy characteristic (e) above. ...