Search - consideration

The Company charged the GST on the consideration for the supply of the leased TPP to the Customer. 12. ...

. […] EXPLANATION Generally, every recipient of a taxable supply (other than a zero-rated supply) made in Canada is required to pay GST/HST at the rate of 5%, 13%, 14% or 15% (depending on the place of supply) on the value of the consideration for the supply. ... For purposes of the exemption outlined in section 2 of Part II of Schedule V, section 138 may apply to deem particular supply of property or services to form part of the single supply of an institutional health care service where it is reasonable to regard the particular supply as incidental to the other supply, and where both supplies are made for a single consideration. ...

The amount of consideration paid for a supply and whether that amount is tax-included is a private or contractual matter between a supplier and his or her clients. ... This means that, […], it was your clients who were paying the GST on the consideration for your services rather than the GST coming off the amount you received for your services. ...

Subsection 259(1) defines "qualifying funding" of the operator of a facility for all or part of a fiscal year of the operator to mean a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property or services that are made available or rendered at the facility during the fiscal year or part and is paid or payable by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ...

XXXXX the consideration for this supply is payable monthly and the fees are based on a daily amount. ... In addition to the accommodation and basic amenities, residents in this Program receive a comprehensive care and services package entitling them to all the services of the XXXXX as well as the services offered under the XXXXX as well as higher levels of supervision and personal assistance for a single consideration. 4. ...

The policy also stipulates that these modules are to be in as finished condition as possible prior to leaving the manufacturer's premises, taking into consideration that they must be transported. ... Using similar logic, a particular unit that is not physically attached to land should not necessarily be precluded from consideration as a "residential unit" if other relevant factors support its inclusion in the definition. ...

All possible benefits, both direct and indirect, accruing to members must be taken into consideration in determining the tax status of a membership. ... These are not insignificant discounts when compared to the consideration for a XXXXX or XXXXX Membership in XXXXX. ...

In this context, XXXXX would like the CCRA to confirm the following three corollaries that it has presented: Corollary #1: IMs in Canada — XXXXX pays GST on consideration and wants ITCs (investment advice as input to commercial activities of XXXXX; #2 offshore IMs (GST remitted in error by XXXXX on behalf of XXXXX pension plan, subsequently returned by way of rebate) — XXXXX wants a ruling to the effect that XXXXX does not have to self-assess GST because of paragraph 217(a)(i) of the ETA (supply is excluded from definition of "Imported taxable supply" where it is acquired for consumption, use or supply exclusively in the course of commercial activities of the person"); and #3 XXXXX wants ruling that it is entitled to full ITCs on GST paid to Canadian IMs)[,] and 3. ... When contracting for the supply of services to the trusts, prior to XXXXX, as the person liable under the agreement to pay the consideration for the supply of investment management services, is the "recipient," under the terms of the ETA, of the investment management services provided to the trusts by its investment managers (both resident and non-resident). ...

Subsection 259(1) defines "qualifying funding" of the operator of a facility for all or part of a fiscal year of the operator to mean "a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property that are made available, or services that are rendered, at the facility during the fiscal year or part and is paid or payable by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ... Medical funding of a supplier in respect of a supply means an amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the supplier in respect of health care services for the purpose of financially assisting the supplier in making the supply or as consideration for the supply by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ...

Subsection 259(1) defines “qualifying funding” of the operator of a facility for all or part of a fiscal year of the operator as meaning “a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property that are made available, or services that are rendered, at the facility during the fiscal year or part and is paid or payable by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made.” ... Subsection 259(1) defines “medical funding” of a supplier in respect of a supply to be “an amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the supplier in respect of health care services for the purpose of financially assisting the supplier in making the supply or as consideration for the supply by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made.” ...