Search - consideration

2 January 1996 Ruling Case No. 11950-- summary under Subsection 153(1) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(1) Ruling that where land was donated to the local County, the value of the consideration was equal to the value of the right granted by the County to avoid a legal liability to clean up the land. ...

28 May 2004 Ruling RITS 47263-- summary under Taxable Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Taxable Supply Operating subsidies provided by the Ontario Ministry of Health and Long-Term Care to the operator of a nursing home constituted a grant and not consideration for a supply. ...

The Accommodation Fee was consideration for a single supply of a residential unit so that it was exempt under s. 6 of Part 1 of Sched. ...

The Accommodation Fee was consideration for a single supply of a residential unit so that it was exempt under s. 6 of Part 1 of Sched. ...

31 October 2011 Ruling Case No. 136392-- summary under Sale Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Sale The granting of easements in consideration for a single lump sum payment was ruled to be a supply of real property by way of sale even though under the governing law the easements could not be granted for an unlimited term. ...

31 October 2011 Ruling Case No. 136392-- summary under Subsection 221(2) Summary Under Tax Topics- Excise Tax Act- Section 221- Subsection 221(2) The granting of easements in consideration for a single lump sum payment was ruled to be a supply of real property by way of sale even though under the governing law the easements could not be granted for an unlimited term. ...

30 November 1997 Ruling 9732433 F- UTILISATION DE PERTES LOSS UTILIZATION-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Consideration of the reasonableness of an interest rate (8.7%) before giving favourable rulings on an arrangement respecting the deductibility of interest on money borrowed in order to redeem shares that had permitted the utilization of losses within a corporate group. ...

DC has no subsidiaries other than Newco, which it incorporated for nominal consideration. ... DC transferred (DC Transfer 1) the Canadian Transferred Business (which included the accounts receivable, trade receivables, inventories, prepaid expenses and business assets) to Newco in consideration for the assumption of liabilities, the issuance of a promissory note (Newco Debt) and the issuance of common shares, with a s. 85(1) election being filed. ... DC will become legally obligated to make the DC Cash Transfer and to transfer the Newco Common Shares and a loan receivable (the DC Receivable) from Newco to TCo in consideration for the assumption of a portion of the debt, owing by DC to a non-resident indirect subsidiary of Foreign Parentco, equal in amount to the DC Receivable and, respecting the transferred Newco share and DC Cash Transfer, for the assumption of liabilities and the issuance of TCo Preferred Shares. ...

5 April 2004 Ruling Case No. 50019-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service The quarterly fees received in arrears (based on the market value of the investment portfolio) by an investment manager with full discretion as to all investment decisions were consideration for taxable supplies by it given that the primary service provided by it was expertise in the selection of securities, which was characterized as the provision of investment advice. ...

S.212(1)(b)(vii) applies to interest on the debt obligation (and no part of the consideration for the unit need be allocated to the warrant). ...