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GST/HST Interpretation

3 September 1999 GST/HST Interpretation HQR0001904 - Bingo Associations

Please note that amounts retained by the bingo associations from bingo revenues are, generally, regarded as consideration for those taxable services. ... On a related matter, member charities would be entitled to a 50% Public Service Body rebate in respect of tax paid on the consideration for services provided by the bingo associations. ...
GST/HST Interpretation

20 August 1999 GST/HST Interpretation HQR0001902 - Re: ss 183(1)

20 August 1999 GST/HST Interpretation HQR0001902- Re: ss 183(1) Unedited CRA Tags ETA 183(9); ETA 183(1) From: Guerra, Marilena Sent: Friday, August 20, 1999 11:25 AM To: XXXXX Subject: RE: ss 183(1) As per your e-mail dated July 20, 1999 you have asked us to comment whether subsection 183(9) and consequently 183(1) applies to the transactions under consideration in the agreement provided. ... " Subsection 183(1) states, "(w)here at any time after 1990 property of a person is, for the purpose of satisfying in whole or in part a debt or obligation owing by the person to another person (in this section referred to as the "creditor"), seized or repossessed by the creditor under a right or power exercisable by the creditor (other than a right or power that the creditor has under, or because of being a party to, a lease, licence or similar arrangement by which the person acquired the property), a) for the purposes of this Part, the person shall be deemed to have made, and the creditor shall be deemed to have received, at that time, a supply by way of sale of the property; b) for the purposes of this Part (other than sections 193 and 257), that supply shall be deemed to have been made for no consideration; c) where the supply referred to in paragraph (a) is a taxable supply of real property, for the purposes of sections 193 and 257, the tax payable in respect of the supply shall be deemed to be equal to tax calculated on the fair market value of the property at that time; and d) where the supply referred to in paragraph (a) is a supply of real property included in section 9 of Part I of Schedule V, in section 1 of Part V.1 of that Schedule or in section 25 of Part VI of that Schedule, for the purposes of sections 193 and 257, the supply is deemed to be a taxable supply and the tax payable in respect of the supply is deemed to be equal to tax calculated on the fair market value of the property at that time. ...
GST/HST Interpretation

10 May 1999 GST/HST Interpretation HQR0000851 - PROPOSED LAW [Application of the GST/HST to the Supply of Bookkeeping Services]

Under the proposed amendment, where a registrant, who is a member of a designated XXXXX, sells goods or provides services to another registrant, who is also a member of the network, in exchange for units, the member supplying the goods or services would have to charge GST/HST calculated on the value of the consideration, where applicable. However, the member receiving the services would not have to charge tax on the provision of the units since subsection 181.3(5) deems the units to be supplied for nil consideration. ...
GST/HST Interpretation

2 February 1999 GST/HST Interpretation HQR000008 - Qualifying Non-profit Organization

As well, if in order to file the documents requesting an arbitration, the applicant must agree to pay all costs that relate to the arbitration process, those fees may be consideration for the exempt filing of the documents, whether they are paid at the time of the filing or after the arbitration is concluded. ... Where a person is engaged in making taxable supplies for consideration in the course of commercial activities, the person is eligible to fully recover the tax paid or payable on purchases acquired for use, consumption and supply in the course of making the taxable supplies by claiming input tax credits (ITCs). ...
GST/HST Interpretation

30 December 1998 GST/HST Interpretation HQR0001002 - Subsection 177(1.1) of the Excise Tax Act

. •   The agent records an accounts receivable in its books and records for the consideration and the tax payable by the recipient. •   At a future date, the accounts receivable is determined to be uncollectible; the agent writes off the bad debt in its books of account in accordance with generally accepted accounting principles. •   The supply is made after April 23, 1996. •   The principal, the agent and the recipient are dealing at arm's length. ... These conditions include: (1) the person must have made a taxable supply, other than a zero-rated supply, for consideration and (2) the supplier and the recipient of the taxable supply must have dealt at arm's length. ...
GST/HST Interpretation

22 December 1998 GST/HST Interpretation HQR0000858 - "Administrative Services"

Because XXXXX is currently paying a discounted amount to XXXXX for the $XXXXX "coupons", for total consideration of $XXXXX per "coupon", the "coupons" no longer satisfy one of the conditions specified under Policy Paper P-202, which states that the consideration given for the "gift certificate" must equal the stated value on the "certificate". ...
GST/HST Interpretation

27 October 2000 GST/HST Interpretation 8255/HQR0001861 - GST Application on Telecommunication Line Charges

The amount of the consideration relating to the Canadian portion should be calculated on a direct line distance basis between the two Canadian end points. ... The consideration for the deemed supply in each province is calculated based on the proportional distance over which the telecommunication would be transmitted in the province if the telecommunication were transmitted solely by means of cable and related telecommunications facilities located in Canada that connected, in a direct line, the transmitters for emitting and receiving the telecommunications. ...
GST/HST Interpretation

19 October 2000 GST/HST Interpretation 8128/HQR0001734 - Application of Goods and Services Tax (GST) - Parking Operations -

The amendment is proposed to apply to supplies for which consideration becomes due after 1996 or is paid after 1996 without having become due unless the charity has already treated the supply as taxable. Accordingly, supplies of parking by the Foundation (other than by way of sale) will be exempt where the consideration for such supplies became due after 1996 or was paid after 1996 without having become due, except where the Foundation charged or collected any amount as or on account of tax in respect of the supply on or before Announcement Date (October 4, 2000). ...
GST/HST Interpretation

7 September 2000 GST/HST Interpretation 31714 - PROPOSED LAW [Supplies Made to Under the Video Lottery Terminal (VLT) Program]

The percentage share that the VLT owners and siteholders receive is consideration for supplies to XXXXX under the program that are deemed not to be supplies by virtue of subsection 188.1(4) (as proposed to be amended). ... Therefore, the owners and siteholders will not have to charge tax on the percentage share of the net income that they receive as consideration for these supplies. ...
GST/HST Interpretation

9 August 2000 GST/HST Interpretation 8400 - Lawyer's Disbursements - Expert Witness

As previously explained, the expert report/testimony fees are not incurred as agent by the law firm, but an input to the supply of legal services and therefore form part of the consideration payable by the client for the legal services (whether or not the amounts are shown separately in the billing to the client). To the extent that the legal services are taxable (other than zero-rated) supplies the law firm, as a GST/HST registrant, would consequently be required under subsection 221(1) of the Excise Tax Act to collect tax on the value of the consideration for those services. ...

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