Search - consideration

5 January 2012 Ruling Case No. 98811 [broker charge for securing health plan employer]-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service broker charge for securing health plan employer A commission charged by a broker to the administrator of a private health services plan in consideration for bringing the administrator and employer together and designing the plan was consideration for a taxable supply. ...

7 September 2000 Ruling 11830-1B (Case 26962)-- summary under Section 138 Summary Under Tax Topics- Excise Tax Act- Section 138 A supply of booth space together with chairs and tables to exhibitors by a registered charity hosting a conference relating to its objects was deemed in light of s. 138 to be a single supply of real estate which was exempt, given "that the provision of the tables and chairs does not materially affect the amount of consideration charged." CRA stated: we consider a supply to be incidental to a particular supply if the supplier's primary objective is to provide the particular supply, and if the consideration would be the same or only marginally different if only the particular supply were made. ...

16 December 2003 Internal T.I. 2003-04616-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares With respect to the situation where a parent corporation ("Parentco") would elect to have s. 50(1) apply in respect of the shares of one of its wholly-owned subsidiaries ("Lossco") and then, in a subsequent taxation year, Parentco disposes of its Lossco shares in favour of another wholly-owned subsidiary ("Profitco") for a nominal cash consideration, the Agency commented that it would be difficult for Parentco to satisfy the requirements of ss.50(1)(b)(iii)(A) and (C) stating that "the benefits that can be derived from the utilization of non-capital losses should generally be taken into consideration in assigning a value to the shares of a corporation". ...

16 December 2003 Internal T.I. 2003-04616-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) With respect to the situation where a parent corporation ("Parentco") would elect to have s. 50(1) apply in respect of the shares of one of its wholly-owned subsidiaries ("Lossco") and then, in a subsequent taxation year, Parentco disposes of its Lossco shares in favour of another wholly-owned subsidiary ("Profitco") for a nominal cash consideration, the Agency commented that it would be difficult for Parentco to satisfy the requirements of ss.50(1)(b)(iii)(A) and (C) stating that "the benefits that can be derived from the utilization of non-capital losses should generally be taken into consideration in assigning a value to the shares of a corporation". ...

16 October 2012 External T.I. 2012-0439151E5- RRSP strips and prohibited investments-- summary under Registered Plan Strip Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Registered Plan Strip Respecting an expressed concern that the sale of a prohibited investment by an RRSP or RRIF to the annuitant for fair market value consideration may be viewed as an RRSP strip notwithstanding that the transaction is expressly excluded from the "swap transaction" definition, CRA stated: if a prohibited investment held by an RRSP or RRIF is sold by the RRSP or RRIF to the annuitant of the RRSP or RRIF for cash consideration equal to the fair market value of the prohibited investment, the sale transaction will not be treated as an RRSP strip. ...

23 December 2013 Internal T.I. 2013-0514701I7- Bitcoins-- summary under Subsection 153(1) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(1) sale for Bitcoins When asked to address the HST/GST consequences of buying and selling goods in exchange for Bitcoins, CRA stated: [W]here a taxable supply… is made and the consideration for that supply is Bitcoins, the consideration for the supply is deemed to be equal to the fair market value of the Bitcoins at the time the supply is made….For example, if a GST/HST registrant sells a good for 10 Bitcoins and the sale is subject to GST/HST, the registrant will be required to collect the GST/HST calculated on the fair market value of the 10 Bitcoins at the time of the sale. ...

CRA stated: The scenario you have described results in an employee disposing of the employee’s rights under a stock option for consideration equal to the stock option’s intrinsic or in-the-money value where the consideration is paid in employer treasury shares. ...

23 March 2011 Internal T.I. 2010-0389081I7 F- Disposition of a resource property-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) deferred share consideration potentially not recognized until issuance The Vendor sold a percentage interest in mineral claims for consideration including shares to be issued by the public-company purchaser, to be issued over a four-year period. ...

14 April 2009 External T.I. 2007-0238221E5 F- Rights of musician-Transfer-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) s. 56(2) not applicable where copyright or royalty interests transferred at FMV As part of a general response respecting the transfer of rights by a musician to a corporation, CRA stated: As illustrated by … IT-335R2 [para. 8] …the sale of a property for consideration less than its fair market value could result in the application of subsection 56(2). On the other hand, the sale of copyright or royalty interests for consideration equal to their fair market value will generally not trigger subsection 56(2). ...

11 January 2010 External T.I. 2009-0340591E5 F- Specified class- 256(1.1) of the Act-- summary under Subsection 51(1) Summary Under Tax Topics- Income Tax Act- Section 51- Subsection 51(1) s. 51(1) exchange regarded as the new shares having been issued for consideration equalling the FMV of the old shares Where a shareholder exchanged all its Class A shares for Class B shares of the same corporation pursuant to what CRA accepted as being a s. 51 exchange, CRA characterized the Class B shares as having been issued, for purposes of the test in s. 256(1.1)(e), for consideration equalling the FMV of the exchanged Class A shares. ...