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GST/HST Interpretation

31 August 2007 GST/HST Interpretation 92770 - TIB B-032R Registered Pension Plans

Interpretation Given As explained in our letter XXXXX, section 232 of the ETA permits an adjustment, refund or credit of the GST in two situations: where an excess amount of tax has been charged or collected; or where consideration for a supply is reduced at some time after the tax has been charged or collected, and the supplier adjusts, refunds or credits the tax charged on the original consideration. ... Where the supplier has reduced the consideration for a supply and adjusts, refunds or credits the tax charged or collected on the reduced consideration, paragraph 232(3)(a) of the ETA requires either a credit note to be issued by the supplier or a debit note to be issued by the recipient containing prescribed information for documentary purposes. In Scenario 4, if the supplier has reduced the consideration for the returned goods and the recipient has issued a debit note containing the prescribed information, both the supplier and recipient must account for the tax contained as part of the prescribed information on the debit note in their respective reporting periods in which the debit note was issued and received. ...
GST/HST Interpretation

22 August 1995 GST/HST Interpretation 11995-4[2] - Application of the GST to Freight Transportation Services

The XXXXX assessment is consideration for taxable supplies made to the XXXXX members. ... Indicative of this is the fact that if a member chose to show its assessment on its customer's invoice, this would not reduce the amount of the consideration for the freight service. 3. ... Such a practice does not reduce the consideration for the freight transportation service. ...
GST/HST Interpretation

23 September 1997 GST/HST Interpretation HQR0000808 - Taxable Status of Room and Board

Interpretation Requested The XXXXX Regional office has recently received x letters on the topic of room and board and each has illustrated unique aspects for consideration. ... The supplies must be made for a single consideration where the fees are not billed as different or separate supplies. ... As the supply of accommodations is exempt from the GST pursuant to paragraph 6(a) of Part [I] of Schedule V to the Act, the total consideration attributable to the accommodation and laundry services will not be subject to the GST. ...
GST/HST Interpretation

28 September 1998 GST/HST Interpretation HQR0001103 - GST Treatment of Recreation Centres Supplied Concurrently with Residential Complexes

In other words is the deposit part of the consideration for the residential complex? ... XXXXX, stipulates that all the rents payable are consideration for the supply of the land and common areas. Thus each type of rent established by the lease constitutes part of the consideration for that supply regardless of the specific expense to which the rent is attributable. ...
GST/HST Interpretation

6 August 1999 GST/HST Interpretation HQR0001779 - Repairs of Leased Vehicles and Insurance Claims

In this particular case, the recipient is the person who is liable to pay the consideration for the supply of the repair services. It is a question of fact as to who is liable to pay the consideration for the supply (i.e., the recipient of the supply). ... The act of paying the GST/HST does not make the lessor liable to pay the consideration for the supply. ...
GST/HST Interpretation

7 May 1999 GST/HST Interpretation HQR0001534 - Transfer of Beneficial Interest

This transfer may or may not be for consideration based on fair market value or for nil or nominal consideration. ... The supply of the life estate and the supply of the fee simple in remainder of the XXXXX acre parcel deemed under section 269 of the Act to be made by the estate to XXXXX and XXXXX, respectively, are further deemed by that section to be for consideration equal to the amount determined under the Income Tax Act to be the proceeds of disposition of those interests in the property. ... Accordingly, section 155 of the Act would deem the consideration to be equal to the present fair market value of the remainder interest. ...
GST/HST Interpretation

24 March 1999 GST/HST Interpretation HQR0001567 - Cow/Calf Leasing Arrangements

The payment of a fixed amount from the Operator to Owner, is viewed as consideration for the lease of zero-rated farm livestock pursuant to the operation of subsection 136(1) and section 1 of Part IV of Schedule VI. ... The calves represent consideration for the lease of zero-rated farm livestock pursuant to the operation of subsection 136(1) and section 1 Part IV of Schedule VI. ... Owner pays a fixed amount to the Operator as consideration. Owners owns all calves produced from these cows. ...
GST/HST Interpretation

8 January 2003 GST/HST Interpretation 43463 - Payments Made to Clergy, Church Organists and Soloist/Musicians

For your information, GST/HST does not apply to a donation where the donation is not consideration for a supply. If a donor receives something of value, the amount of the donation could be considered consideration for a supply. A gift at common law is considered a voluntary transfer of property without consideration. ...
GST/HST Interpretation

19 July 2023 GST/HST Interpretation 241308 - Application of GST to profit sharing amounts paid by an insurance broker to its parent company

It is a question of fact whether a supply, or supplies, was made by Holdco1 to BrokerCo and whether the payments received by Holdco1 are consideration for those supplies. ... Based on the limited information provided, it is not clear whether Holdco1 made a supply or supplies to BrokerCo for which the payments by BrokerCo were consideration. ... For example, management services may be supplied by the parent company to its subsidiary, for which consideration is paid. ...
GST/HST Interpretation

21 July 2023 GST/HST Interpretation 241678 - Application of GST to profit sharing amounts paid by an insurance broker to its parent company

It is a question of fact whether a supply, or supplies, was made by Holdco1 to BrokerCo and whether the payments received by Holdco1 are consideration for those supplies. ... Based on the limited information provided, it is not clear whether Holdco1 made a supply or supplies to BrokerCo for which the payments by BrokerCo were consideration. ... For example, management services may be supplied by the parent company to its subsidiary, for which consideration is paid. ...

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