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Kang v. M.N.R., 2005 TCC 24

Keays stated he considered that 3 cheques- tabs 91, 92 and 93- payable to Ravjit Gill and totalling $6,900 had been negotiated prior to his last day of work and amounted to $500 more than his alleged net pay according to the statement at tab 94, without taking into consideration several cash payments alleged to have been received by Gill from time to time over the course of his employment. ... Mah stated the rulings issued by her with respect to SRC workers were the first ones in her career requiring consideration of whether certain employments were an outright sham and/or if others were tainted by suspicious records and/or other fraudulent documentation. ... When one considers the overhead of paying drivers and operating vans and taking into consideration other business expenses, SRC would have lost between $20 and $30 every day just by employing Ajmer Kaur Gill to pick raspberries. ...

28 September 2011 GST/HST Interpretation 135932 - GST/HST Interpretation - [...] [Supplies of design, construction, financing and management services of a facility]

To the extent that any consideration become payable before January 1, 2008, the GST at 6% applies to that consideration. ... Subsection 168(2) provides that, notwithstanding subsection 168(1), where consideration for a taxable supply becomes due on more than one day, tax is payable on the day any part of the consideration becomes due and is based on the consideration that becomes due on that day. As the consideration for the construction of the [facility] was not paid by Hospital Authority at any time before consideration for the supply became due, it must be determined when consideration for the supply became due. ...

26 February 2001 GST/HST Interpretation 33311/HQR0001582 - — Eligibility to Claim ITC

If the consideration for the Services was included in the total consideration paid, the ITCs claimed would be for inputs to an exempt supply, as the sale of Accounts was a financial service and no GST was charged or remitted on the supply. ... The Registrant states that the supply of the Services is made for no consideration, and there is no consideration directly linked to this supply in contracts: therefore any claim under either of these subsections for ITCs related this supply must fail. ... The specified purpose for which XXXXX receives consideration is the sale of the Accounts. ...

6 September 1995 GST/HST Interpretation 1995-09-06 - Application of GST to Coins Denominated in U.S. Currency Which are Collected by the ("the Town") in its Coin-operated Parking Meters

This should not be confused with the actual consideration given for a supply. Although in many supplies the amount of consideration given and the value of consideration are the same, there will be instances where the two amounts are different. In such instances it is the value of consideration which is the base on which tax is calculated and not the amount of consideration actually given. ...

3 July 2002 GST/HST Interpretation 34735 - Sale of Real Property to

" Pursuant to subsection 153(1), the "value of the consideration is... deemed to be equal to (a) where the consideration... is expressed in money, the amount of the money; and (b) where the consideration... is other than money, the fair market value of the consideration at the time the supply is made. ... This corresponds to the concept of "valuable consideration" at common law (A frequently cited definition of "consideration" at common law is from Lush J. in Currie v. ... " In the present situation, then, the tax on the consideration paid by the Association in XXXXX is subject to tax in that year, notwithstanding that the consideration is, in part, for the supply of the long-term lease made in XXXXX (the remainder being consideration for the Interim Lease). ...

2004 Ruling 2004-0099651R3 - Migration to Canada / PUC Reduction

The licensing arrangement will be for a period of XXXXXXXXXX years, and S3Co will pay to ACo as consideration, a lump-sum amount. ...

15 April 2008 Internal T.I. 2008-0266251I7 - Liechtenstein foundation

The rulings, which follow the OECD's August 16, 1999, report on the application of the OECD model tax treaty to partnerships, reverse positions previously taken by the Ministry of Finance, which used to take only one feature into consideration- the separate legal personality of the foreign entity. ...

5 October 2007 APFF Roundtable, 2007-0242441C6 F - Gains ou pertes sur taux de change

With respect to the capital payment, the capital gain or loss should be calculated by taking into consideration the above-mentioned position. ...

31 October 2011 External T.I. 2011-0422981E5 F - Whether property is eligible for a bump

If the marketable securities are transferred by the parent to the subsidiary and, as consideration for that transfer, the parent acquires shares of the subsidiary and, at the same time, control of the subsidiary (in a case, for example, where the parent would not have been the incorporator of the corporation), would the marketable securities be eligible for the bump under paragraph 88(1)(c)? ...

16 November 2011 External T.I. 2011-0419191E5 - Foreign Intermediaries & Canadian Owners

Policy considerations surrounding compliance, the language of the Act, and the clear purpose behind Part XIII do not allow for relief through an expansion of the certification system. ...

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