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GST/HST Interpretation
31 March 2006 GST/HST Interpretation 63336 - Cemetery property and/or services under a pre-need arrangement
Under the provisions of subsection 168(1), the tax, if applicable, is payable by the recipient of a taxable supply on the earlier of the day that consideration for the supply is paid and the day that the consideration becomes due. ... Under the provisions of subsection 152(1), the consideration for the supply is due on the day the supplier issued the ticket and, pursuant to subsection 168(1), the tax, if applicable, is payable by the recipient of the supply on the day the consideration was paid (i.e., at the time of sale). ... An agent who is registered for the GST is required to collect tax from the principal on the value of the consideration for its service. ...
Current CRA website
Definitions under the digital-economy measures
Accommodation platform operator Accommodation platform operator, in respect of a supply of short-term accommodation made through an accommodation platform, means a person (other than the supplier or an excluded operator in respect of the supply) that meets any of the following conditions: The person controls or sets the essential elements of the transaction between the supplier and the recipient If the above condition does not apply to any person, the person is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier The person is a prescribed person (no person is currently prescribed) Canadian accommodation related supply Canadian accommodation related supply means a taxable supply of a service that meets both of the following conditions: It is made to a person in connection with a supply of short-term accommodation situated in Canada made to the person The consideration for the service represents a booking fee, administration fee or other similar charge Digital platform Digital platform includes a website, an electronic portal, gateway, store or distribution platform or any other similar electronic interface but does not include either of the following: An electronic interface that solely processes payments A prescribed platform or interface (no platform or interface is currently prescribed) Distribution platform operator Distribution platform operator, in respect of a supply of property or a service made through a specified distribution platform, means a person (other than the supplier or an excluded operator in respect of the supply) that meets any of the following conditions: The person controls or sets the essential elements of the transaction between the supplier and the recipient If the above condition does not apply to any person, the person is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier The person is a prescribed person (no person is currently prescribed) Electronic filing Electronic filing means using electronic media in a manner specified by the Minister. Excluded operator Excluded operator, in respect of a supply of property or a service, means any of the following: A person that meets all of the following conditions: The person does not set, directly or indirectly, any of the terms and conditions under which the supply is made The person is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply The person is not involved, directly or indirectly, in the ordering or delivery of the property or in the ordering or rendering of the service A person that solely provides for the listing or advertising of the property or service or for the redirecting or transferring to a digital platform on which the property or service is offered A person that is solely a payment processor A person that is a prescribed person (no person is currently prescribed) False statement False statement includes a statement that is misleading because of an omission from the statement. ... Qualifying tangible personal property supply Qualifying tangible personal property supply means a supply made by way of sale of tangible personal property that is, under the agreement for the supply, to be delivered or made available to the recipient in Canada, other than: An exempt or zero-rated supply A supply of tangible personal property sent by mail or courier to the recipient at an address in Canada from an address outside Canada by the supplier or by another person acting on behalf of the supplier, if the supplier maintains evidence satisfactory to the Minister that the property was so sent A prescribed supply (no supply is currently prescribed) Recipient Recipient of a supply of property or a service means: If consideration for the supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration If the previous bullet does not apply and consideration is payable for the supply, the person who is liable to pay that consideration If no consideration is payable for the supply: In the case of a supply of property by way of sale, the person to whom the property is delivered or made available In the case of a supply of property otherwise than by way of sale, the person to whom possession or use of the property is given or made available In the case of a supply of a service, the person to whom the service is rendered Any reference to a person to whom a supply is made shall be read as a reference to the recipient of the supply. ...
GST/HST Interpretation
6 October 2003 GST/HST Interpretation 8479 - Grant of Joint Tenancy with a Reservation for a Life Estate
The question then arises as to whether any tax is payable since the conveyance is made without consideration. ... Where a non-arm's length taxable supply is made for no consideration or for consideration that is less than fair market value of the supply, and the recipient is a non-registrant, this provision deems the consideration to be equal to the fair market value of the supply. ... Further, since there is no consideration for this supply, subsection 155(1) will deem there to be taxable consideration equal to the fair market value of the licence to use that portion. ...
Archived CRA website
ARCHIVED - Reassessment Where Option Exercised in Subsequent Year
Consideration may be received by grantors of options to acquire property or to dispose of property, in connection with the granting, extension, or renewal of such options. Subject to the comments in 8 below (concerning the granting of options by individuals to acquire property), where in a particular taxation year receipt of such consideration has resulted in the inclusion of an amount in the grantor's income and the option is exercised in a later year, subsection 49(4) provides a means of removing from the grantor's income for the prior year the effect of the consideration received. 2. ... In the case of an option to acquire, no upward adjustment of the proceeds of disposition of the property is required and, in the case of an option to dispose, no downward adjustment of the cost of the property is required, in respect of the consideration received by the grantor of the option. ...
Old website (cra-arc.gc.ca)
Sustainable Development Action Plan for 2011-2014 - April 1, 2011 to March 31, 2014
., My Account, My Business Account, Benefit Online Application, Automated Benefit Application, Electronic Transfer of Accounting Data) ABSB, CPB, LPRAB, TSDMB/- /- 2.1.1.2 Establish criteria and measure the SD benefits of CRA electronic services (Annual) SD benefits are measured F&A (SD)/ ABSB, CPB, LPRAB, TSDMB/- Objective 2.2: Increase CRA outreach and communications Long-term outcome: Taxpayers and benefits recipients use CRA self-service options Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 2.2.1: Canadians have greater access to tax and benefits information through outreach activities Measure: Type of outreach events and number of participants 2.2.1.1 Increase the number of groups targeted for outreach events and integrate SD considerations and messages into outreach activities and communication (2014) Outreach events that incorporate SD considerations; SD messages are on the National Outreach Coordinating Committee website ABSB, CPB, PAB, TSDMB/ F&A (SD)/- 2.2.1.2 Measure and communicate the SD benefits of CRA outreach activities (Annual) Report on SD benefits of outreach activities F&A (SD)/ TSDMB, PAB /- Goal 3: Improve business sustainability Objective 3.1: Improve sustainability in human resources management Long-term outcome: Sustainable workforce Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 3.1.1: Employees have increased access to electronic training and learning options Measure: New e-learning products and processes 3.1.1.1 Integrate SD messages in human resources communications and products related to recruitment, career management, and healthy and respectful workplace (Annual) By 2014, SD messages in recruitment campaigns (e.g., external student/ graduate hiring, good practices on telework, Respectful Workplace Site) HRB/ F&A (SD)/- 3.1.1.2 Increase and promote electronic options to minimize the need for printed training and learning materials (2014) New electronic training and learning options HRB/ F&A (SD)/- Target 3.1.2: SD awareness among employees is maintained at a minimum of 90% Measure: Percentage of employees aware of SD at the CRA 3.1.2.1 Develop and promote an SD online learning product for employees (2014) Online SD learning product is available for employees; online knowledge transfer guide for MGs and ECs; e-learning solutions for auditors by 2014 F&A (SD)/ HRB (TLD)/- 3.1.2.2 Continue to deliver the SD module within the F&A training session of MGLP (Annual) SD module in MGLP is delivered F&A (SD)/ HRB/- 3.1.2.3 Modernize the SD Program management and communication (2014) SD accountabilities are integrated into job functions; wiki application by 2012 F&A (SD), SD Network/ HRB/- 3.1.2.4 Conduct the SD Awareness Survey (2014) SD Awareness Survey Report F&A (SD)/ PAB (EPMD, POREAD)/ EKOS Objective 3.2: Incorporate SD in information technology processes Long-term outcome: Sustainable information technology services and infrastructure Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 3.2.1: SD considerations are integrated into the life cycle management of IT processes and infrastructure Measure: Types of SD considerations included in IT management 3.2.1.1 Integrate SD criteria in ITB project templates (2014) SD criteria in project templates ITB/ F&A (SD)/- 3.2.1.2 Integrate SD considerations into ITB training and learning products (Annual) IT training/ learning products include SD (i.e., Welcome Aboard and Setting the Compass) ITB/ F&A (SD)/- 3.2.1.3 Measure and communicate SD benefits associated with IT improvements (2013) Report on SD benefits of IT improvements ITB/ F&A (SD)/- Objective 3.3: Integrate SD into CRA accountability framework Long-term outcome: SD is part of the corporate culture Target and measure Activity Output Accountability (OPI/OCI/Partner) Target 3.3.1: SD is integrated into corporate accountability framework Measure: Types of corporate documents and templates that have integrated SD 3.3.1.1 Integrate SD into corporate plans and reports (Annual) SD integrated into RPP/CBP, DPR/ Annual Report F&A (SMPSD)/ SIB, SD Network/- 3.3.1.2 Continue integrating SD measures in EC performance agreements and MG performance expectations (Annual) SD measures integrated in 100% of EC performance agreements and 90% of MG performance expectations HRB, SIB/ F&A (SD)/- 3.3.1.3 Integrate SD criteria into key corporate templates (Annual) SD criteria integrated in key Agency templates (RIMC, Strategic Investment, Benefits Measurement Plan, FACS) F&A (RMD, SMPSD)/ CAEB/ F&A (SD) 3.3.1.4 Use the SD Criteria Tool to integrate SD considerations into CRA policies, programs, plans, and projects (2014) CRA Policies, programs, plans, and projects include sustainability criteria ABSB, CPB, HRB, ITB, TSDMB/ F&A (SD)/- 3.3.1.5 Update the SD Line of Enquiry for use in internal audits (2012) SD Line of Enquiry updated CAEB/ F&A (SD)/- Next page Previous page Date modified: 2011-06-15 ...
Current CRA website
Extension of Transfer Payment Policy
GST/HST Policy Statement P-061 DATE OF ISSUE May 25, 1993 SUBJECT Extension of Transfer Payment Policy LEGISLATIVE REFERENCE(S) Definitions of 'consideration' and 'supply', subsection 123(1) of the Excise Tax Act. ... Furthermore, is the financial assistance not consideration for a supply and therefore outside the scope of the ETA? RULING GIVEN: None of the financial assistance is consideration for a supply, nor is it a supply in itself. ...
Scraped CRA Website
ARCHIVED - Reassessment Where Option Exercised in Subsequent Year
Consideration may be received by grantors of options to acquire property or to dispose of property, in connection with the granting, extension, or renewal of such options. Subject to the comments in 8 below (concerning the granting of options by individuals to acquire property), where in a particular taxation year receipt of such consideration has resulted in the inclusion of an amount in the grantor's income and the option is exercised in a later year, subsection 49(4) provides a means of removing from the grantor's income for the prior year the effect of the consideration received. 2. ... In the case of an option to acquire, no upward adjustment of the proceeds of disposition of the property is required and, in the case of an option to dispose, no downward adjustment of the cost of the property is required, in respect of the consideration received by the grantor of the option. ...
GST/HST Interpretation
31 March 2014 GST/HST Interpretation 143163 - Application of the GST/HST to the supply of a right of entry or user under section 162
As per the Agreements, Disposal Co. 1 and Disposal Co. 2 agree to pay the Landowner on behalf of Oil Co. 1 and Oil Co. 2 respectively, consideration for the supply of the use of the land for the disposal of the drilling waste. 5. Currently the Landowner is collecting and remitting GST on the […][consideration]. 6. ... Any consideration paid or payable for the supply of the right of entry or user would not be subject to the GST/HST. ...
GST/HST Interpretation
9 July 2008 GST/HST Interpretation 79280 - Application of GST/HST to Instalment Payment Charges
As explained herein, the CRA's position is that these amounts are consideration for taxable supplies, and not consideration for exempt supplies. ... We learned that some funeral homes and cemetery operators have not charged or accounted for GST/HST on these amounts based on information provided by the CRA in 1994, that the amounts were consideration for exempt supplies of financial services. ... After careful consideration of the issue, we have concluded that the instalment payment charges are consideration for taxable supplies. ...
GST/HST Interpretation
22 June 2010 GST/HST Interpretation 117433 - Purchase of Loyalty Program Miles
The value of the consideration would be the costs of the flight less the discount allowed for the miles redeemed. ... As such, the processing fee would be additional consideration for the purchase of the miles and, accordingly, the fee for the miles and the processing fee would be subject to GST/HST. 4. ... The fee charged by the service provider to the member for the re-supply of the miles, the recovery of any taxes and other charges and any transaction or processing fee would be all part of the consideration for the supply of the miles made by the service provider to the member; the total consideration payable to the service provider by the member for the re-supply of the miles would be subject to GST/HST as applicable. ...