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GST/HST Ruling

30 January 2025 GST/HST Ruling 248887 - […][Product Name] […][modular furniture] and accessories

The accessories and accessory sets under consideration for this ruling request are called […][Accessory Set 1], […][Accessory Set 2], […][Accessory Set 3], and […][Accessory Set 4], and have the following attributes: [Accessory Set 1] Described on the website product description as: […] [Accessory Set 2] Described on the website product description as: […] [Accessory Set 3] Described on the website product description as: […] [Accessory Set 4] Described on the website product description as: […] 6. ... EXPLANATION Generally, in accordance with section 165 of the ETA, every recipient of a taxable supply made in Canada is required to pay GST/HST on the value of the consideration for the supply, unless the supply is zero-rated (listed in Schedule VI to the ETA and subject to the GST/HST at the rate of 0%) or exempt (listed in Schedule V to the ETA and not subject to the GST/HST). ...
GST/HST Ruling

15 February 2019 GST/HST Ruling 147979 - Recaptured Input Tax Credits (RITCs) on Specified Energy

Paragraph (a) of the definition of recipient in section 123 of the ETA describes a recipient as, where consideration for a supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration. […][In your correspondence,] you state that the Office Component Owners receive the electricity invoices which are in their name only and they also hold the contract with the utility company. ... It was held in Telus Communications (Edmonton) Inc., vs The Queen, 2008 TCC 5, paragraph 13, that the "recipient" was by definition the person liable to pay the consideration under the agreement for the supply. It also held that the recipient of a supply is not a person required to pay the supplier an amount equal to the consideration payable under the agreement on account of a liability of that person which arose as a consequence of a separate supply or agreement between that person and that recipient. ...
GST/HST Ruling

17 May 2012 GST/HST Ruling 117014 - Application of the GST/HST to various fees and reimbursed expenses

The letter also included the following documents for our consideration: * […] Corporate Structure (Flow Chart). * […] (LP Agreement). * […] (Management Agreement). * […] (Partnership Offering Memorandum). * […] (Investment Management Agreement). * […] (Fund Offering Memorandum). * […] (Service Agreement). ... The Service Agreement further notes that in consideration for the Managers services, the Advisor will pay […] per month to the Manager as an Investment Management Fee plus an annual Performance Bonus, and will at all times keep the Manager fully indemnified against all expenses arising out of the performance of its services under the Agreement. ... The Investment Management Agreement also notes that in consideration for the Advisor’s services, the Fund will pay a monthly Management Fee to the Advisor as well as a Performance Fee set out in the Fund Offering Memorandum as follows: a) A monthly Management Fee calculated on […] b) An annual Performance Fee for […] 22. ...
GST/HST Ruling

6 July 2011 GST/HST Ruling 101290 - [...] [GST/HST Treatment of Recreational Vehicle Sites]

We will assume that the consideration for such rentals exceeds $20 for each day of occupancy. 15. ... The maintenance fee charged by the Developer to the Sublessees is additional consideration for the taxable supply of an RV Site made under the RV Site Sublease and accordingly, is subject to the GST/HST. 9. ... The fee is viewed as additional consideration for the taxable supply of the RV Site made under the RV Site Sublease. ...
GST/HST Ruling

5 January 2011 GST/HST Ruling 125981 - Application of HST to Fees for International Fuel Tax Agreement (IFTA) Decals and The Reimbursement of Costs of Coloured Dye [in Ontario]

The reimbursement of the cost of dye by a registered dyer under subsection 4.18(4.3) is consideration for a taxable supply of the dye and therefore, is subject to the GST/HST. ... Reg 22/97, the $10 per set of decals is consideration for a single supply of a licence/permit provided by the Minister. ... The reimbursement is consideration for the supply of the dye by the Minister to the registered dyer and it is subject to GST/HST. ...
GST/HST Ruling

5 September 2006 GST/HST Ruling 54497 - Independent Medical Examinations and Other Independent Assessments

All possible benefits accruing to members must be taken into consideration in determining the tax status of a membership. ... Paragraph 17(d) of Part VI of Schedule V Under paragraph 17(d) of Part VI of Schedule V, the right to receive or acquire property or services supplied to the member for consideration that is not part of the consideration for the membership and that is equal to the "fair market value" of the property or services at the time the supply is made is an allowable benefit. Under subsection 123(1), "fair market value" is defined as meaning the fair market value of a property or a service supplied to a person without reference to any tax excluded by section 154 from the consideration for the supply. ...
GST/HST Ruling

3 July 2024 GST/HST Ruling 242566r - GST/HST on fees or charges for capital costs

RULING GIVEN Based on the facts set out above, we rule that the Municipality’s charges to the Company towards the Cost of Expansion are consideration for a taxable supply of wastewater treatment services that is subject to the GST/HST. EXPLANATION Generally, every recipient of a taxable supply (other than a zero-rated supply) made in Canada is required to pay the GST/HST on the value of the consideration for the supply. ... Accordingly, the charges by the Municipality to the Company for the Cost of Expansion are consideration for the supply of wastewater treatment services. ...
GST/HST Ruling

23 March 2023 GST/HST Ruling 244917 - GST/HST implications of constructing a laneway house

The [...] form states that the total consideration and the value of the real property (land, building, fixtures and goodwill) purchased by the Owners was $[…]. 4. ... The management fee paid to [Corporation C] is consideration for a taxable supply and as indicated in the addendum to the Agreement, HST applies to this supply. ... In turn, a payment of consideration and tax made by the recipient of a supply of real property that is held in joint tenancy is a payment made to all of the joint tenants. ...
GST/HST Ruling

25 February 2019 GST/HST Ruling 179132 - S - Children’s workshops, camps, […][professional development day camps], and events

There is a maximum number of participants and participants can be added for additional consideration. 36. ... The tutoring/instruction program provides a series of levels of attainment which every child must complete without consideration of the child’s specific needs in respect of a school authority’s course or curriculum. ... ADDITIONAL INFORMATION Input tax credits Generally, a GST/HST registrant is eligible to claim input tax credits (ITCs) to recover the GST/HST it pays to the extent that its purchases and expenses are inputs into making taxable supplies for consideration. ...
GST/HST Ruling

25 May 2020 GST/HST Ruling 187870a - Lease of real property

EXPLANATION Generally, every recipient of a taxable supply (other than a zero-rated supply) is required to pay GST/HST on the value of the consideration for the supply. ... Where these amounts form part of the total consideration for the supply of real property, even though these amounts may be charged separately, they will take on the same tax status as the rent. ... These additional rents form part of the consideration for the lease of the Premises made under the Lease Agreement and will take on the same tax status as the lease. ...

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