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GST/HST Interpretation

19 March 2008 GST/HST Interpretation 100748 - Amount Charged on Direct Recoverable Costs

The Company calculates the GST on the total value of consideration (fees for service + disbursements). ... Therefore, the reimbursement for these expenses form part of the consideration for the supply. ... However, as the client's agent, the Company will usually pay the consideration and applicable GST to the supplier of the property and/or services. ...
GST/HST Interpretation

13 March 2008 GST/HST Interpretation 92312 - Amount charged on direct recoverable costs

On the other hand, if the analysis concludes that there are multiple supplies supplied together for a single consideration it is necessary to determine if a particular supply is incidental to another and deemed by section 138 to form part of that supply.  ... Where it is determined that section 138 does not apply and at least one of the multiple supplies provided together for a single consideration is a supply of a financial service, then the application of section 139 should be considered. Section 139 is a mixed-supply rule that sets out conditions under which the supply of a number of separable financial services, non-financial services, and properties for a single consideration are treated as a supply of only financial services.  ...
GST/HST Interpretation

8 June 1995 GST/HST Interpretation 11865-2/39 - The Supply of a Health Care Service Made by an Ophthalmologist

The GST status of the consideration paid by a XXXXX for the use of a clinic (cost of using facilities) owned and operated by the partnership. ... Conversely, any consideration paid to or retained by the partnership is consideration paid for a supply to the self-employed practitioner of, staff, office space, telephone service and other overhead expenses and is subject to the GST. ... Consideration paid to the partnership by the practitioner is consideration paid for the supply of staff, office space, telephone service, other overhead expenses and is subject to the GST at the rate of 7%. ...
GST/HST Interpretation

17 June 2002 GST/HST Interpretation 34567 - Application of the GST/HST to Convenience Fees

Consideration charged to users will exceed the direct cost of the good. A XXXXX convenience fee on the gross sale amount is included in the consideration charged to users. ... The GST/HST will apply to consideration paid by consumers for online goods. ...
GST/HST Interpretation

25 September 2003 GST/HST Interpretation 42635 - Registrant Trade-ins Involving Outstanding Liens

The Lessor is making a supply of the leased vehicle to the Lessee, and accepting the trade-in as partial consideration for that supply. ... There are two taxable supplies being made, and GST will apply to the full consideration on both of them. The Lessor would charge GST on the full consideration for the leased vehicle including the trade-in value, and the Lessee would charge GST on the value of the trade-in. ...
Archived CRA website

ARCHIVED - Eligible Capital Amounts

However, where consideration for the disposition of eligible capital property is dependent upon the use of or production from that property, such consideration does not give rise to an eligible capital amount but rather is simply included in income. ... He receives consideration for disclosing the process and allowing it to be used by the payer. ... The characterization of the consideration is a question of fact, although isolated transactions usually result in a disposition of EC property. 4. ...
Old website (cra-arc.gc.ca)

False or misleading information

False or misleading information Under subsection 237.1(7.4), every person: who files false or misleading information in Form T5001- Application for Tax Shelter Identification Number and Undertaking to Keep Books and Records, or who as a principal or as an agent sells, issues or accepts consideration for an interest in a tax shelter before the minister of national revenue has issued an identification number, is liable to a penalty that is the greater of: a $500 penalty, and 25% of the greater of: the total of all consideration received or receivable in respect of the tax shelter before the correct information is filed with the Minister, or the identification number is issued, and the total of all amounts stated or represented to be the value of property a person who acquires or invests in the tax shelter could donate to a qualified donee, if the tax shelter is a gifting arrangement and consideration has been received or is receivable before the correct information is filed with the Minister, or the identification number is issued. ...
Current CRA website

False or misleading information

False or misleading information Under subsection 237.1(7.4), every person: who files false or misleading information in Form T5001- Application for Tax Shelter Identification Number and Undertaking to Keep Books and Records, or who as a principal or as an agent sells, issues or accepts consideration in respect of a tax shelter before the Minister of National Revenue has issued an identification number is liable to a penalty that is the greater of both: $500 25% of the greater of both: the total of all consideration received or receivable in respect of the tax shelter before the correct information is filed with the Minister, or the identification number is issued the total of all amounts stated or represented to be the value of property a person who acquires or invests in the tax shelter could donate to a qualified donee, if the tax shelter is a gifting arrangement and consideration has been received or is receivable before the correct information is filed with the Minister, or the identification number is issued Forms and publications Form T5001, Application for Tax Shelter Identification Number and Undertaking to Keep Books and Records Report a problem or mistake on this page Thank you for your help! ...

10 May 2019 GST/HST Ruling 167225 - Royalty Payments -- summary under Supply

10 May 2019 GST/HST Ruling 167225- Royalty Payments-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply loan and royalty advance were consideration for single taxable supply of IPP CRA considered a situation in which a financing of a company with product sales was bifurcated into a non-interest-bearing loan and a royalty agreement. ... The second component was styled as a royalty agreement and contemplated that in consideration for a stipulated amount advanced to the company (which was labeled as an “interest free loan”), the company was to start paying a percentage of its product sales to the investor after a stipulated level of payments had been made under the loan agreement. ... Accordingly, there was a taxable supply by the company to the investors, and the “principal amount” advanced by them under their “loan” to the company was the up-front consideration charged to them for this taxable supply. ...

3 September 2019 GST/HST Interpretation 173195 - […][Mutual Fund Units] -- summary under Paragraph (l)

It seemed likely, but unclear, to CRA, based on the limited information provided to it, that such charges were consideration for the service of the Funds in redeeming (or accepting subscriptions for) the units and, therefore, were exempted under para. (d) of the financial services definition as being consideration for the “transfer of ownership” of financial instruments (i.e., it apparently was sufficient, in the redemption situation, that the unitholders ceased to be owners and that it did not matter that there was no new owner of the units – and conversely in the subscription situation). If, on the other hand, the redemption (or subscription) fees were consideration payable to the Fund manager for its service of “arranging for” the “transfer of ownership” of the units, CRA indicated that this created the possibility that such redemption fees were part of a single supply of management services made by the manager (pursuant to a management agreement between it and the unitholders) for periodic management fees. ...

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