Search - consideration

In addition, there is a geographical consideration in that the Foreign Interchange Service was provided to a non-resident merchant acquirer while expenses to redeem the points are incurred by RBC in Canada. … [E]xpenses incurred by RBC in the redemption of loyalty reward points were inextricably linked and an integral component of the Appellant’s agreement to extend credit pursuant to the Cardholder Agreement. ...

This was accomplished by transferring their co-ownership interests on a s. 85(1) rollover basis to respective Newcos (“HP Newco”, in the case of Harvard Properties) in consideration inter alia for voting and non-voting shares, followed by a sale of those voting shares to an Abacus subsidiary (NH Properties) for promissory notes for under half of the sale price. ...

Skolrood JA found that there were no reversible errors in the findings of the chamber judge that it was appropriate to “unbundle” the single consideration that GFL charged on a monthly basis to its customers for BC PST purposes: 80% to the non-taxable waste disposal service; and 20% to the taxable lease of the toilets and to the cleaning services provided “to” the toilets. ...

GPDI would charge the merchant a merchant discount fee of, say, 2%, and pay CIBC an interchange fee of, say, 1.5% in consideration for CIBC’s authorization and payment services. ...

The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Specified Provincial Input Tax Credit Summary Under Tax Topics- Excise Tax Act- Section 236.01- Subsection 236.01(1)- Specified Provincial Input Tax Credit Bell Canada received single supplies of electricity from its Ontario electricity suppliers so that their full charges were subject to provincial ITC recapture The appellant (Bell Canada) was required as a result of ETA s. 236.01 and Part 6 of the New Harmonized Value-added Tax System Regulations, No. 2 (the “Recapture Regulations”) to recapture 100% of the input tax credits that it claimed in respect of the 8% tax that it paid under s. 165(2) on the consideration for the supplies to it in Ontario of electricity. ...

The Queen, 2017 TCC 212 (Informal Procedure)-- summary under Substantial Renovation Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Substantial Renovation gutting only half the rooms in a house did not qualify The taxpayer appealed a decision of the Minister to reject his claim for a GST new housing rebate on the basis that the building “looked like new”, the CRA’s analysis was flawed, and that drywall should be excluded from consideration. ...

ECL assigned the loan note to a Honduras company ("Industrias") which was also owned by ECL, in consideration of the issue by Industrias to ECL of loan notes with the same principal amount and carrying interest at 4% p.a. ...

In rejecting the Crown's position that such 20% share was taxable consideration for administrative, billing and marketing services supplied to the sleep physicians by MedSleep, Bodie J found that: The fee-sharing agreements were valid for tax purposes notwithstanding that, under provincial health care law, payments for physicians’ services could be made by the provincial health insurance plans to physicians only; and The fee-sharing agreements did not contemplate that MedSleep would provide the alleged admin and marketing services to the sleep physicians and they instead indicated that MedSleep was entitled to a portion of the professional fees generated from medical services provided to the patients. ...

Thus, in light of these and other considerations, the only date for applying the connected test that seemed to “work” was the December 31 trust year end. ...

. … Under Article 5(2)(i) of the DTAA, the relevant consideration is the continuity of business presence in aggregate – not the length of stay of each individual employee. ...