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In finding that the supplies of T-shirts by the charity to the donors were not exempt, with HST or GST applying on the consideration of $X for each supply of a T-shirt, CRA stated: excluded from exemption under paragraph 3(a) of Part V.1 of Schedule V is a supply by way of sale of any personal property or service made by a charity in the course of a fund-raising activity where: • the charity makes supplies of such property or services in the course of that activity on a regular or continuous basis throughout the year (any period of twelve consecutive months) or a significant portion (30% or more) of the year; or • the agreement for the supply entitles the recipient to receive from the charity property or services on a regular or continuous basis throughout the year or a significant portion of the year.....as XXXXX supplied the t-shirts to contributors on a weekly basis from XXXXX to early XXXXX, it sold the t-shirts on a regular and continuous basis throughout a significant portion of the year. ...

In finding that the supplies of T-shirts by the charity to the donors were not exempt, with HST or GST applying on the value of $X for each supply of a T-shirt, CRA stated:...where the charity provides the person making the contribution with property or a service of more than nominal value that served as an inducement to make the contribution, then for ETA purposes, the amount of the contribution is not regarded as a gift but as consideration for the supply of the property or service given in return by the charity. ...

Salesco and OpCo2 purchase for cancellation all the issued and outstanding Class A shares (held by USSalesco1) for cash or promissory note consideration equal to the shares' fair market value. ...

The estate will transfer its remaining Class A shares to Newco in consideration for Newco issuing Note 2 (with an amount equal to the ACB of the transferred shares) and a common share, with a joint election being made under s. 85(1). ...

Proposed transactions In order to simplify the structure: Foreign Parent will acquire from Foreign Holdco for no consideration the shares of Canco2; and Canco2 will purchase all the shares of Canco1 from Foreign Parent in exchange for Canco2 common shares with an equivalent fair market value, but with their paid-up capital limited by s. 212.1. ...

Proposed transactions The Trust will transfer its shares of A Co to its newly-incorporated subsidiary ("Newco") in consideration for a note equal to their combined fair market value and for a preferred share, electing under s. 85(1). ...

Pubco will transfer its shares of Canco and Forco1, and a loan owing by Forco1, to Newco mostly in consideration for interest-bearing notes of Newco- as well as the issuance of preferred shares with a nominal redemption amount and subject to a price adjustment clause. ...

Pubco will transfer its shares of Canco and Forco1, and a loan owing by Forco1, to Newco mostly in consideration for interest-bearing notes of Newco- as well as the issuance of preferred shares with a nominal redemption amount and subject to a price adjustment clause. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...

Holdco2 will transfer the US Loan to Holdco1 in consideration for a demand Canadian-dollar interest-bearing promissory note. ...