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Results 23661 - 23670 of 29044 for consideration
Ruling
2024 Ruling 2024-1027391R3 - Upstream loans
Canco will sell all of its shares of CFA to Forco 1 for cash consideration equal to their fair market value. ...
Technical Interpretation - External
23 June 2020 External T.I. 2020-0849221E5 F - SSUC - Entité déterminée et institution publique
De plus, le paragraphe 149(1.1) de la Loi prévoit que pour déterminer les critères de propriété de 100 % et de 90 % prévus aux alinéas 149(1)d) à d.6) de la Loi, tout droit d’acquérir des actions ou du capital d’une société devrait être pris en considération, comme si le droit avait été exercé. ...
Technical Interpretation - Internal
4 November 1999 Internal T.I. 9912267 F - TRANSFERT CREDIT FRAIS DE SCOLARITÉ
Non-résident- règle générale À notre avis, les tribunaux ont toujours suivi le principe selon lequel un contribuable doit être sujet à une cotisation en vertu de la Partie I de la Loi avant d'être pris en considération dans le cadre de l'application d'une disposition de la Loi. ...
GST/HST Ruling
28 July 2006 GST/HST Ruling 81356 - GST Rate Change on Purchase of Hotel Rooms
With respect to determining when consideration becomes due, subsection 152(1) provides that the consideration, or a part thereof, for a taxable supply shall be deemed to become due on the earliest of (a) the earlier of the day the supplier first issues an invoice in respect of the supply for that consideration or part and the date of that invoice, (b) the day the supplier would have, but for an undue delay, issued an invoice in respect of the supply for that consideration or part, and (c) the day the recipient is required to pay that consideration or part to the supplier pursuant to an agreement in writing. ... Therefore, pursuant to paragraph 152(1)(c), the consideration for the supply is deemed to become due on the day the purchaser is required to pay that consideration or part to the Company pursuant to the Agreement. As a result, and pursuant to subsection 168(2), the purchaser is required to pay GST/HST on the supply of the memorialization merchandise on the earlier of the day he/she pays the consideration or part and the day he/she is required to pay the consideration or part under the Agreement. ...
GST/HST Interpretation
24 April 1996 GST/HST Interpretation 11643-2 - Non-Compliance Fees (Ruling Requests from )
Instead, the settlement would be regarded as consideration for a claim or right to a claim. ... Regardless, consideration due from XXXXX would generally be attributed to a single supply of the particular property. ... Where subsection 182(2) applies, XXXXX would be deemed to have made to the supplier a taxable supply for consideration equal to the consideration fraction (i.e. 100/107ths) of the amount of debt extinguished. ...
GST/HST Interpretation
29 August 2000 GST/HST Interpretation 32293 - Barter Transactions
This section provides, in part, that if the value of the consideration for the supply is expressed in money, the value of the consideration will be the amount of money. However, if all or a part of the consideration for the supply is other than money, the value of the consideration is equal to the fair market value of the consideration or that part at the time the supply was made. Subsection 153(2) of the Act provides that where consideration is paid for a supply and other consideration is paid for one or more other supplies or matters, and the consideration for one of the supplies or matters exceeds the consideration that would be reasonable if the other supply were not made or the other matter were not provided, the consideration for each of the supplies and matters must be reasonably attributed to each of those supplies and matters. ...
GST/HST Interpretation
29 July 2004 GST/HST Interpretation 53446 - Tax Status of Services Provided by a Sales Representative
The general rule of subsection 168(1) provides that GST/HST is payable by the recipient (in this case, the municipality) of a taxable supply on the earlier of the day the consideration for the taxable supply is paid and the day the consideration becomes due. ... Subsection 152(1) provides that consideration (payment) is due on the earlier of the day that the supplier first issues an invoice in respect of the supply or the day that the supplier would have, but for an undue delay, issued an invoice or the day the recipient is required to pay that consideration pursuant to an agreement in writing. ... However, the determination of when tax is payable is determined on a case-by-case basis after consideration of all the facts. ...
GST/HST Interpretation
6 September 2000 GST/HST Interpretation 8384 - Supplies Between a Charity and an Operator Under an Agreement
With respect to the XXXXX retained by the Operator, paragraph 153(1)(b) of the ETA provides that where the consideration for a supply (or part of the consideration) is other than money, the value of the consideration or that part is deemed to be the fair market value of the consideration or that part at the time the supply is made. ... It is consequently at this time that the consideration for the sorting and processing services is considered to have been paid. Subsection 152(3) of the ETA provides that where consideration that is not money is given or required to be given, the consideration that is given or required to be given shall be deemed to be paid or required to be paid, as the case may be. ...
GST/HST Interpretation
23 June 2006 GST/HST Interpretation 80206 - PROPOSED LAW/REGULATION GST rate reduction and lease contracts
Pursuant to subsection 168(1) of the ETA, the tax in respect of a taxable supply is payable on the earlier of the day the consideration for the supply is paid and the day the consideration for the supply is due. ... Consideration due under the agreement on or after July 1, 2006 Where the consideration for the supply is due under the agreement on or after July 1, 2006 and the recipient of the supply does not pay the consideration prior to July 1, 2006, the tax becomes payable on or after July 1, 2006 as the case may be. ... Subsection 168(1) of the ETA provides that tax in respect of a taxable supply is payable by the recipient on the earlier of the day the consideration for the supply is paid and the day the consideration for the supply becomes due. ...
GST/HST Interpretation
5 June 2009 GST/HST Interpretation 114562 - The Application of Section 141.01 to an Annual Golf Tournament and Awards Dinner
In making a determination of whether the consideration for a supply is more than nominal, does the Canada Revenue Agency look at the entire consideration received for the event or each supply of an admission separately? ... Subsection 141.01(1.1) provides that "consideration" does not include nominal consideration in subsections 141.01(1.2), (2) and (3). ... In the situation you presented where XXXXX charges consideration for the supply of the right to play golf to an individual GST/HST must be collected on the consideration since such a supply is taxable. ...