Search - consideration

XCo purchases 11% of the outstanding shares of FAOpco from Canco for fair market value consideration, which at that time is $500,000. ... FA1 incorporates a wholly owned subsidiary (“FA4”) and transfers its shares of FA2 to FA4 in exchange for share consideration. ...

Where certain conditions are met, the proposed changes provide that a participating employer and a master trust may jointly elect to have every actual taxable supply made by the employer to the master trust be deemed to have been made for no consideration. ... GST/HST forms GST59, GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges GST111, Financial Institution GST/HST Annual Information Return GST303, Application to Offset Taxes by Refunds or Rebates GST507, Third Party Authorization and Cancellation of Authorization for GST/HST Rebates RC79, Deposit Advice RC145, Request to Close Business Number Program Accounts RC151, GST/HST Credit Application for Individuals Who Become Residents of Canada RC193, Service-Related Complaint RC4288, Request for Taxpayer Relief- Cancel or Waive Penalties or Interest RC4607, GST/HST Pension Entity Rebate Application and Election RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes RC4617, Election and Schedule to a Return for Simplified Reporting of Specified Housing Supplies RC7190-WS, GST190 Calculation Worksheet RC7207, GST/HST Rebate Application and Election for GST/HST and QST Purposes for Pension Entities that are Selected Listed Financial Institutions RC7207-1, QST Rebate Application and Election for Pension Entities that are Selected Listed Financial Institutions for GST/HST Purposes Only RC7291, GST/HST and QST Annual Information Return for Selected Listed Financial Institutions RC7321, Delegation of Authority for Certain Selected Listed Financial Institutions RC7345, Request to Close Business Number Program Accounts for Certain Selected Listed Financial Institutions GST/HST guides RC4022, General Information for GST/HST Registrants RC4027, Doing Business in Canada- GST/HST Information for Non-Residents RC4028, GST/HST New Housing Rebate RC4034, GST/HST Public Service Bodies' Rebate RC4036, GST/HST Information for the Travel and Convention Industry RC4052, GST/HST Information for the Home Construction Industry RC4058, Quick Method of Accounting for GST/HST RC4082, GST/HST Information for Charities RC4231, GST/HST New Residential Rental Property Rebate RC4419, Financial Institution GST/HST Annual Information Return RC7219, GST/HST and QST Annual Information Return for Selected Listed Financial Institutions GST/HST info sheets GI-188, New Brunswick and Newfoundland and Labrador HST Rate Increases – Sales and Rentals of Non-residential Real Property GI-189, New Brunswick and Newfoundland and Labrador HST Rate Increases – Information for Non-registrant Builders GI-190, New Brunswick and Newfoundland and Labrador HST Rate Increases – Sales and Rentals of New Housing GI-191, New Brunswick and Newfoundland and Labrador HST Rate Increases – Stated Price Net of the GST/HST New Housing Rebate GI-192, Prince Edward Island HST Rate Increase – Sales and Rentals of Non-residential Real Property GI-193, Prince Edward Island HST Rate Increase – Information for Non-registrant Builders GI-194, Prince Edward Island HST Rate Increase – Sales and Rentals of New Housing GI-195, Prince Edward Island HST Rate Increase – Stated Price Net of the GST/HST New Housing Rebate GST/HST notices NOTICE300, Déline First Nation Ratification of their Final Self-Government Agreement NOTICE301, Prince Edward Island HST Rate Increase – Questions and Answers on General Transitional Rules for Personal Property and Services NOTICE302, Prince Edward Island HST Rate Increase – Questions and Answers on Housing Rebates and Transitional Rules for Housing and Other Real Property Situated in Prince Edward Island GST/HST policy statements P-255, Late-filed Section 156 Elections and Revocations All GST/HST, excise duty and excise taxes and special levies publications can be found on the CRA website at cra.gc.ca/gsthsttech, at cra.gc.ca/etsl and at cra.gc.ca/exciseduty. ...

Example A taxpayer relief request made by a person (for GST/HST or non-GST/HST purposes) during the 2010 calendar year will only be eligible for consideration for a reporting period that ended in 2000 or subsequent calendar years. Due to the 10-year rolling time limit, a taxpayer relief request made on or after January 1, 2011, will not be eligible for consideration for a reporting period that ended in the 2000 or prior calendar years. ... GST/HST forms GST44- Election Concerning the Acquisition of a Business or Part of a Business GST59- GST/HST Return for Imported Taxable Supplies and Qualifying Consideration GST66- Application for GST/HST Public Service Bodies' Rebate and GST Self-government Refund GST190- GST/HST New Housing Rebate Application for Houses Purchased from a Builder GST497- Election under the Special Attribution Method for Selected Listed Financial Institutions and Notice of Revocation GST521- GST/HST Multi-Employer Pension Plan Trust Rebate Application GST523-1- Non-profit organizations- Government Funding GST531- Return for Self-Assessment of the First Nations Goods and Services Tax (FNGST) RC4601- GST/HST Reporting Entity and Tax Adjustment Transfer Elections and Revocations for a Selected Listed Financial Institution RC4602- Request for a Group GST/HST Registration Number for Selected Listed Financial Institutions with Consolidated Filing RC4603- GST/HST Tax Adjustment Transfer Election and Revocation for a Selected Listed Financial Institution RC4604- GST/HST Reporting Entity, Consolidated Filing and Tax Adjustment Transfer Elections and Revocations for a Selected Listed Financial Institution RC4605- Total Tax Recovery Rate Election and Revocation for a Selected Listed Financial Institution RC4606- Election or Revocation for a Qualifying Small Investment Plan to be Treated as a Selected Listed Financial Institution RC4607- GST/HST Pension Entity Rebate Application and Election GST/HST info sheets GI-096- Harmonized Sales Tax: Provincial Transitional New Housing Rebates for Housing in Ontario and British Columbia GI-101- Harmonized Sales Tax: Information for Non-registrant Builders of Housing in Ontario, British Columbia and Nova Scotia GI-102- Nova Scotia HST Rate Increase: Sales and Rentals of Non-residential Real Property GI-103- Nova Scotia HST Rate Increase: Progress Payments and Holdbacks GI-104- Nova Scotia HST Rate Increase: Sales and Rentals of New Housing GI-108- Applying the 2010 Nova Scotia HST Rate Increase- Personal Property GI-109- Applying the 2010 Nova Scotia HST Rate Increase- Services GI-110- Applying the 2010 Nova Scotia HST Rate Increase- Admissions and Memberships GI-111- Applying the 2010 Nova Scotia HST Rate Increase- Transportation Services and Passes GST/HST notices Notice253- Harmonized Sales Tax for Ontario and British Columbia- Questions and Answers for Public Service Bodies (revised) Notice257- For discussion purposes only: The GST/HST Rebate for Pension Entities Notice258- Reminder- Letter of Good Standing for Claiming the Ontario and British Columbia Provincial Transitional New Housing Rebates Notice259- Information Requirements Related to Investments in Selected Listed Financial Institution Distributed Investment Plans (other than Exchange-traded Funds) Excise tax and special levies forms B200- Excise Tax Return N15-1- Excise Tax Act, Application for Refund/Rebate, Supplementary Information Excise duty notices EDN25- Sale of Unstamped Partially Manufactured Tobacco and Activities of a Tobacco Licensee EDN26- New Excise Stamp Security Features Air travellers security charge forms B253- Softwood Lumber Products Export Charge- Registration Form B253-1- Softwood Lumber Products Export Charge- Independent Remanufacturer Registration Supplement B253-2- Softwood Lumber Products Export Charge- Registration Supplement- Multiple Regions or Mills B275- Softwood Lumber Products Export Charge Return Softwood lumber products export charge notices SWLN29- Surge Charge- Alberta Region (August 2010) SWLN30- Notice to Independent Remanufacturers- Calculation of the Yield Loss Percentage SWLN31- Surge Charge- Alberta Region (September 2010) SWLN32- Surge Charge- Alberta Region (October 2010) 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. ...

This is not intended to be an exhaustive list as each case may be negotiated differently and warrant different considerations based on its particular fact situation. ... However, the deductibility of remuneration is unclear where subsection 78(4) applies to a non-contingent liability accrued by a company (“A Co”) which liability is assumed by another company (“B Co”) as part of the consideration paid for the purchase of A Co’s business (including its employees). ... The CRA will take into consideration how the taxpayer reports under the new accounting standards as part of our review of the taxpayer's determination of profit under GAAP. ...

This is not intended to be an exhaustive list as each case may be negotiated differently and warrant different considerations based on its particular fact situation. ... However, the deductibility of remuneration is unclear where subsection 78(4) applies to a non-contingent liability accrued by a company (“A Co”) which liability is assumed by another company (“B Co”) as part of the consideration paid for the purchase of A Co’s business (including its employees). ... The CRA will take into consideration how the taxpayer reports under the new accounting standards as part of our review of the taxpayer's determination of profit under GAAP. ...

What are the tax considerations? It is only possible to receipt the transfer of a time-share if ownership of the deed title is first transferred to the donor then transferred to the charity. ... In cases where there is consideration, a business may claim these costs as promotional expenses, rather than seeking a charitable donation. ...

In urgent circumstances, the CRA will expedite consideration of these applications. ... To learn more about the disbursement quota, see: Annual spending requirement: www.cra.gc.ca/tx/chrts/prtng/spndng/menu-eng.html and, the disbursement quota checklist: www.cra.gc.ca/tx/chrts/chcklsts/dq-eng.html Split receipting Split receipting is a descriptive term used by the CRA for issuing tax receipts for a portion (the “eligible amount of a gift”) of an amount transferred to a registered charity where the donor receives an advantage (consideration) in return for a donation. ...

Paragraph 115(2)(d) deems a non-resident to have been employed in Canada in a particular taxation year, for purposes of subsection 2(3), if the non-resident was in that year one of the following persons: (a) a student in full-time attendance at a university, college or other educational institution in Canada which provides courses at a post-secondary school level in Canada; (b) a student attending or a teacher teaching at a university, college, or other educational institution outside Canada providing courses at a post-secondary school level, if that student or teacher had ceased in a previous year to be resident in Canada in the course of or after moving to attend or teach at that educational institution; (c) an individual who had ceased in a previous year to be resident in Canada in the course of or after moving to carry on research or any similar work under a grant received by the individual to enable him or her to carry on that research or work; (d) an individual who had ceased in a previous year to be resident in Canada and who in the current year received remuneration from an office or employment paid directly or indirectly by a person resident in Canada; or (e) a person who received an amount in the current year under a contract, if the amount was or will be deductible by a taxpayer subject to Part I tax and can reasonably be regarded as having been received in whole or in part, regardless of when the contract was entered into or the form or legal effect of the contract, as (i) consideration or partial consideration for entering into a contract of service or for services to be performed in Canada (i.e., a signing bonus- see the current version of IT-168), or for undertaking not to enter into such a contract with another party, or (ii) remuneration or partial remuneration from the duties of an office or employment or compensation or partial compensation for services to be performed in Canada. 20. ...

Interest, while not defined in the Act, has been described in general terms in the Courts as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another". ... Applicable to taxation years commencing after 1982, where a taxpayer has accrued and reported interest income on a debt obligation and has at any particular time disposed of the obligation for consideration equal to its fair market value at the time of disposition, the taxpayer may, by virtue of subsection 20(21), deduct in computing income for the year of disposition, the amount, if any, by which the aggregate of the amounts of interest from that debt obligation that was included in the taxpayer's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...

Paragraph 115(2)(d) deems a non-resident to have been employed in Canada in a particular taxation year, for purposes of subsection 2(3), if the non-resident was in that year one of the following persons: (a) a student in full-time attendance at a university, college or other educational institution in Canada which provides courses at a post-secondary school level in Canada; (b) a student attending or a teacher teaching at a university, college, or other educational institution outside Canada providing courses at a post-secondary school level, if that student or teacher had ceased in a previous year to be resident in Canada in the course of or after moving to attend or teach at that educational institution; (c) an individual who had ceased in a previous year to be resident in Canada in the course of or after moving to carry on research or any similar work under a grant received by the individual to enable him or her to carry on that research or work; (d) an individual who had ceased in a previous year to be resident in Canada and who in the current year received remuneration from an office or employment paid directly or indirectly by a person resident in Canada; or (e) a person who received an amount in the current year under a contract, if the amount was or will be deductible by a taxpayer subject to Part I tax and can reasonably be regarded as having been received in whole or in part, regardless of when the contract was entered into or the form or legal effect of the contract, as (i) consideration or partial consideration for entering into a contract of service or for services to be performed in Canada (i.e., a signing bonus- see the current version of IT-168), or for undertaking not to enter into such a contract with another party, or (ii) remuneration or partial remuneration from the duties of an office or employment or compensation or partial compensation for services to be performed in Canada. 20. ...