Search - consideration

Paragraph 18(9)(a) disallows a deduction to the extent that the outlays and expenses can reasonably be regarded as having been made or incurred (a) as consideration for services to be rendered after the end of the year, (b) for interest, taxes (other than taxes on insurance premiums), rent or royalties for a period after the end of the year, or (c) as consideration for insurance for a period after the end of the year, except for (i) consideration for reinsurance, where the taxpayer is an insurer, or (ii) consideration paid after February, 1994, for the life insurance of an individual under a group term life insurance policy where all or part of the consideration is for insurance that is (or would be if the individual survived) for a period that ends more than 13 months after the consideration is paid. ...

The SCC then went on to consider whether or not the payments by the Province to the City were consideration for any supply. ... In conclusion, the SCC sets out a logical approach to determine when a transfer payment is consideration for a supply for purposes of the Act. ... If there is a supply, one must then determine whether the payments are consideration for the supply. ...

Paragraph 18(9)(a) disallows a deduction to the extent that the outlays and expenses can reasonably be regarded as having been made or incurred (a) as consideration for services to be rendered after the end of the year, (b) for interest, taxes (other than taxes on insurance premiums), rent or royalties for a period after the end of the year, or (c) as consideration for insurance for a period after the end of the year, except for (i) consideration for reinsurance, where the taxpayer is an insurer, or (ii) consideration paid after February, 1994, for the life insurance of an individual under a group term life insurance policy where all or part of the consideration is for insurance that is (or would be if the individual survived) for a period that ends more than 13 months after the consideration is paid. ...

., taxable capital gains minus allowable capital losses) on the disposition of "taxable Canadian properties" (see 9 below) not used or held in the year in the course of carrying on business in Canada (not to exceed net taxable capital gains from all dispositions in the year of taxable Canadian properties) (vii) tax payable under Part I for the taxation year less the portion of that tax attributable to net taxable capital gains specified in (vi) above (viii) non-deductible income taxes payable to a provincial government for the taxation year less the portion of such income taxes attributable to the net taxable capital gains specified in (vi) above (ix) allowance claimed for the year in respect of the investment in property in Canada (applicable only if the corporation was carrying on business in Canada at the end of the taxation year), not exceeding the maximum amount specified in subsection 808(1) of the Regulations (see 13 below) (x) amounts included in computing taxable income earned in Canada for the taxation year in respect of Crown resource royalties or the like, to the extent such amounts are not deductible under (viii) or (ix) above, and taxes paid or payable to the Crown (generally in respect of production or processing of petroleum prior to October 1986- see 19 below) under the Petroleum and Gas Revenue Tax Act, and (xi) excess of fair market value of any "qualified property" disposed of in the taxation year over the sum of the increase in paid-up capital resulting from the disposition plus the fair market value of the non-share consideration received (see 7 below for details) Amount subject to tax under section 219 Non-Canadian Corporations Resident in Canada 6. ... The provisions apply with respect to the transfer of "qualified property" to a Canadian corporation wholly owned by the non-Canadian corporation immediately after the transfer where the consideration received by the non-Canadian corporation includes shares of the Canadian corporation. ... Paragraph 219(1)(k) permits a deduction, in computing the amount subject to tax under section 219, of the amount by which the fair market value of the qualified property at the time of its disposition exceeds the aggregate of the amount of the increase in the paid-up capital of the capital stock of the Canadian corporation as a result of the disposition and the fair market value, at the time of receipt, of any non-share consideration given by the Canadian corporation. ...

., taxable capital gains minus allowable capital losses) on the disposition of "taxable Canadian properties" (see 9 below) not used or held in the year in the course of carrying on business in Canada (not to exceed net taxable capital gains from all dispositions in the year of taxable Canadian properties) (vii) tax payable under Part I for the taxation year less the portion of that tax attributable to net taxable capital gains specified in (vi) above (viii) non-deductible income taxes payable to a provincial government for the taxation year less the portion of such income taxes attributable to the net taxable capital gains specified in (vi) above (ix) allowance claimed for the year in respect of the investment in property in Canada (applicable only if the corporation was carrying on business in Canada at the end of the taxation year), not exceeding the maximum amount specified in subsection 808(1) of the Regulations (see 13 below) (x) amounts included in computing taxable income earned in Canada for the taxation year in respect of Crown resource royalties or the like, to the extent such amounts are not deductible under (viii) or (ix) above, and taxes paid or payable to the Crown (generally in respect of production or processing of petroleum prior to October 1986- see 19 below) under the Petroleum and Gas Revenue Tax Act, and (xi) excess of fair market value of any "qualified property" disposed of in the taxation year over the sum of the increase in paid-up capital resulting from the disposition plus the fair market value of the non-share consideration received (see 7 below for details) Amount subject to tax under section 219 Non-Canadian Corporations Resident in Canada 6. ... The provisions apply with respect to the transfer of "qualified property" to a Canadian corporation wholly owned by the non-Canadian corporation immediately after the transfer where the consideration received by the non-Canadian corporation includes shares of the Canadian corporation. ... Paragraph 219(1)(k) permits a deduction, in computing the amount subject to tax under section 219, of the amount by which the fair market value of the qualified property at the time of its disposition exceeds the aggregate of the amount of the increase in the paid-up capital of the capital stock of the Canadian corporation as a result of the disposition and the fair market value, at the time of receipt, of any non-share consideration given by the Canadian corporation. ...

Consideration is defined in the Act to include any amount payable by operation of law. ... For its services provided to Walkaway under the dealer agreement with Walkaway, Applewood received consideration (calculated as 55% of the insurance premium). ... A person who is registered or required to be registered for GST/HST is required to collect the GST/HST on the consideration (such as a fee) for the supply. ...

Where such an option was exercised in a year subsequent to the one in which it was granted and prior to 1988, none of the consideration received by the grantor in respect of the option will be added to the proceeds of disposition of the property transferred on the exercise of the option, and the grantor's return of income for any prior year will not be adjusted by reason only of the exercise of the option. ...

Where such an option was exercised in a year subsequent to the one in which it was granted and prior to 1988, none of the consideration received by the grantor in respect of the option will be added to the proceeds of disposition of the property transferred on the exercise of the option, and the grantor's return of income for any prior year will not be adjusted by reason only of the exercise of the option. ...

The maximum capital cost allowance that may be claimed in respect of a particular mine or right is the lesser of (a) the amount computed by applying the rate established in accordance with 5 or 6 above to the number of units actually mined during the fiscal period under consideration, and (b) the undepreciated capital cost of the mine or right A taxpayer may, in lieu of claiming capital cost allowance as determined above for all his industrial mineral mines or rights, claim an amount not exceeding the lesser of (a) $100, or (b) the amount received by him in the taxation year from the sale of mineral In such case, the taxpayer, if he has more than one mine or right, may allocate the amount deducted among his mines and rights. ... Where land acquired as an industrial mineral mine is disposed of, the entire consideration received therefore is proceeds of disposition of depreciable property, namely, the industrial mineral mine, and is included in the calculation of the undepreciated capital cost of the class in which the mine is included under paragraph 13(21)(f). ...

For the purposes of these provisions, a gift is a voluntary transfer of real or personal property without valuable consideration. ... The general approach is to value the various interests taking into consideration the fair market value of the property itself, the current interest rates, the life expectancy of any life tenants, and any other factors relevant to the specific case. ...