Search - consideration

It is of this view as it characterizes its commercial activities in connection with the professional liability insurance program as managing and administering, for the benefit of its members and in consideration of their levies, a group insurance program under which insurance is provided by a licensed insurer. ... As such, the XXXXX should be advised that it has charged GST to its members in error; 2) that as a result of the XXXXX also being a recipient of insurance (i.e., coverage C in the group professional liability insurance policy) that a portion of the total amount of the premium charged by the insurer to the XXXXX is for this coverage for which the XXXXX and not its members is the recipient; 3) that the XXXXX is supplying a financial service to the insurer for no consideration to which it is not eligible to claim ITCs, i.e., it is managing and administering an insurance policy for which it is "at risk" within the meaning of the "at risk" rules in the Financial Services (GST) Regulations. This is due to the fact that, in the administrative agreement between the XXXXX and the insurer which is an integral and inseparable part of the insurance contract, the XXXXX has agreed, among other things, to supply an indemnity to the insurer with respect to a portion of the insurers obligation to provide liability insurance coverage to the members of the XXXXX Accordingly, the XXXXX is providing a financial service to the insurer for no consideration. ...

The monthly fee constitutes consideration for the Corporation managing the complex and for the right of the Owner to use a parking space located in the complex. 2. ... A person is a small supplier during any particular calendar quarter and the following month if the total value of the consideration for taxable supplies, including zero-rated supplies, made by the person (or an associate of the person who was an associate at the beginning of the particular calendar quarter, i.e., the calendar quarter in which the calculation is being made) that became due, or was paid without becoming due, in the previous four calendar quarters does not exceed $30,000, or in the case of a public service body, $50,000. The calculation should not include consideration attributable to the sale of goodwill of a business or certain taxable supplies such as supplies of financial services and supplies by way of sale of capital property. ...

Interpretation Given Every recipient of a taxable supply made in Canada is required to pay GST/HST in respect of the supply at the rate of 7% (15% where the supply is deemed to be made in a participating province) on the value of the consideration for the supply unless the supply is zero-rated (taxed at 0%). ... The annual and monthly posting fees and sales commissions charged by CANCO to the vendor are considered by the CCRA to be consideration for the supply of a service of arranging for, procuring or soliciting orders for supplies made by the vendor. ... The service supplied to the purchaser (the consideration for which is recorded as the "buyers premium") may also be zero-rated pursuant to section 5 of Part V of Schedule VI to the Act provided the purchaser is not resident in Canada and the supply by the vendor is made outside Canada or the supply by the vendor is zero-rated pursuant to any of the provisions in Part V of Schedule VI to the Act. ...

Also, the partnership paid the consideration and tax on the improvements to the land. ... This supply was apparently made for no consideration, but the partnership must nevertheless self-assess on the fair market value of the residential complex portion of the property at that point. ... If a portion of the property is not part of the residential complex but was supplied to the individuals by the partnership for their personal use, the supply would be a taxable supply for no consideration, made by a registrant not dealing at arm's length with the recipients of the supply (the individuals). ...

In particular, we were asked whether the fees charged by a regional municipality to a land owner may be deemed to be consideration for an exempt supply under section 189.1. ... Each supplier is making a supply that is independent of the other and each supplier receives consideration for the particular supply that it makes to the recipient. ... If further clarification is required concerning the tax status of the services provided by the regional municipality in connection with the approval of a land development agreement, please provide us with detailed information concerning the transaction(s) in question and all of the relevant documentation for our review and consideration. ...

The following documents were provided to us for our consideration: a) [...] used to evidence: • the registration [...] ... ANALYSIS Our analysis and conclusion are based on facts derived from the standard documents you provided to us for consideration and that are routinely used for [the Community] transactions. ... Additional consideration Fair market value of the residential complex Paragraph 256(2)(b) of the ETA sets out one of the other conditions for claiming a rebate under section 256. ...

., the person who is liable to pay the consideration for the supply) of the initial supply from the third party. ... The definition of "direct cost" was also amended to include the consideration paid by the supplier for the acquisition or importation of the good or service, the GST payable by the supplier, and any tax, duty or fee prescribed for the purposes of section 154 (e.g., provincial sales tax). ... In this case, if the consideration charged by XXXXX was equal to or greater than the direct cost of the bus operator costs, less the GST paid by XXXXX, the resupply was taxable. ...

Provincial and municipal funding Where a grantor makes a payment to a grantee it must be determined whether that payment is consideration for a supply for purposes of the ETA. ... Generally, payments will not be consideration for a supply where the payments are not directly linked to a supply made by the grantee to the grantor or to a specified third party. ... Generally, where a province or municipality provide payments to the Board to financially assist the Board in undertaking its own activities, the payments are not consideration for a supply and are not subject to the HST. ...

The following additional comments are provided for your consideration. ... TIB B-032 indicates that where pension related expenses incurred by the employer (the person liable to pay the consideration under the agreement for the supply) have been paid out of trust assets, the CRA generally considers the payment made by the plan trust1 to be consideration for an actual supply of property or service made by the employer to the trust if: * the trust paid the third party supplier directly, * the employer invoiced the trust for the costs of the inputs, and/or * the trust reimbursed the employer. In such circumstances, the employer would generally be considered to be making a supply of property or services to the trust for which the trust, as recipient of a taxable supply, based on subsection 165(1) would be required to pay tax calculated on the consideration for the supply. ...