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GST/HST Interpretation

8 August 2001 GST/HST Interpretation 36741 - Early Payment Discount

It is your understanding that the discount for early payment of the invoice should not be calculated on the consideration paid for the service plus the GST/HST paid on that consideration. ... Section 161 of the ETA provides that where tangible personal property or services are supplied and the amount of the consideration for the supply shown in the invoice in respect of the supply may be reduced if the amount thereof is paid within a time specified in the invoice or an additional amount is charged to the recipient by the supplier if the amount of the consideration is not paid within a reasonable period specified in the invoice, the consideration due shall be deemed to be the amount of consideration shown on the invoice. ...
GST/HST Interpretation

26 June 2003 GST/HST Interpretation 6353 - Application of GST to Auctioneering Services

The Auctioneer charges its clients a commission as consideration for services it performs with respect to the sale of their livestock. ... In other words, the Auctioneer is not required to collect GST on the commissions it receives from its clients as consideration for services it performs with respect to the sale of their livestock. With respect to the various fees and deductions collected because of provincial legislation, the CCRA's position is that the XXXXX deduction and check-off fee are not consideration for a supply, and consequently, are not subject to the GST. ...
GST/HST Interpretation

24 March 2003 GST/HST Interpretation 44104 - Application of GST/HST to Supplies Made by Way of Monoselectors

Subsection 165.1(2) provides that where the consideration for a supply of tangible personal property or a service is paid by depositing a single coin in a mechanical coin-operated device that is designed to accept only a single coin of twenty-five cents or less as the total consideration for the supply and the tangible personal property is dispensed from the device or the service is rendered through the operation of the device, the tax payable in respect of the supply is equal to zero. ... Suppliers should therefore take this requirement into account when determining the consideration for supplies made through such devices. ... It provides in part that the supplier is deemed to have made the supply, received the consideration for the supply, and collected any tax payable in respect of the supply, on the day when the consideration for the supply is removed from the coin-operated device. ...
GST/HST Ruling

22 January 2003 GST/HST Ruling 35053 - Tax Status of Memberships Supplied by a Non-profit Organization

Explanation Section 17 of Part VI of Schedule V to the ETA exempts the supply of a membership in a public sector body (other than a membership in a club the main purpose of which is to provide dining, recreational or sporting facilities or in a registered party) where each member does not receive a benefit by reason of the membership, other than a) an indirect benefit that is intended to accrue to all members collectively, b) the right to receive services supplied by the body that are in the nature of investigating, conciliating or settling complaints or disputes involving members, c) the right to vote at or participate in meetings, d) the right to receive or acquire property or services supplied to the member for consideration that is not part of the consideration for the membership and that is equal to the fair market value of the property or services at the time the supply is made, e) the right to receive a discount on the value of the consideration for a supply to be made by the body where the total value of all such discounts to which a member is entitled by reason of the membership is insignificant in relation to the consideration for the membership, or f) the right to receive periodic newsletters, reports or publications the value of which is insignificant in relation to the consideration for the membership, or that provide information on the activities of the body or its financial status, other than newsletters, reports or publications the value of which is significant in relation to the consideration for the membership and for which a fee is ordinarily charged by the body to non-members, except where the body has made an election under the section in prescribed form containing prescribed information. ...
Current CRA website

Sustainable Development Action Plan for 2011-2014

., 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 Page details Date modified: 2011-06-15 ...
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. ...

23 April 2019 GST/HST Ruling 186334 - S AND INTERPRETATIONS - Annual licensing fees and public service bodies’ rebate eligibility -- summary under Paragraph 20(c)

23 April 2019 GST/HST Ruling 186334- S AND INTERPRETATIONS- Annual licensing fees and public service bodies’ rebate eligibility-- summary under Paragraph 20(c) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 20- Paragraph 20(c) consideration for licensing included expired licence fees An incorporated non-profit organization (the “Organization”), perhaps a provincial law society, which regulated a profession in a province, made exempt supplies under s. 20(c) respecting the following items: the annual licensing fee expired licence fee (being “additional consideration for supply of a licence”) ...

27 July 2021 GST/HST Interpretation 197267a - Allocation to a general partner -- summary under Paragraph 272.1(3)(b)

Under ss. 272.1(3)(b) and (8), the general partner of the ILP would generally be treated as supplying taxable services to the ILP on a periodic basis (at the end or beginning of each billing period) for deemed value of consideration equaling the FMV of those services – so that such “value of consideration … is not based on the actual amount that the investment limited partnership allocates or otherwise pays to the general partner, unless the amount is a reasonable approximation of the FMV of the services.” Such FMV “should take into consideration the industry standard for the management of investments in comparable situations” which “includes management fees and performance fees”. ...
GST/HST Interpretation

21 June 1994 GST/HST Interpretation 1994-06-21 - Van Purchased in Canada and Subsequently Exported to

Subsection 123(1) of the Act states, in part, that '"recipient" of a supply of property or a service means (a) where consideration for the supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration," I would suggest that a copy of the vehicle sale agreement be obtained from XXXXX. If the agreement for the supply of the van were between XXXXX and XXXXX it is likely that XXXXX would have been liable to pay the consideration, and not the XXXXX orphanage. ...
GST/HST Interpretation

27 September 2000 GST/HST Interpretation 6177 - GST on Shared Cost of Bus Transportation of Students

In your letter, you ask whether the charge by the XXXXX to the XXXXX for the cost of transportation by bus in XXXXX of the XXXXX students qualifies as consideration for an exempt supply under s. 5 of Part III of Schedule V of the Excise Tax Act. You then indicate that even if s. 5 is not applicable, the charge qualifies as consideration for an exempt supply under s. 2 of Part VI of Schedule V. As I indicated in our telephone conversation, we believe that the charge qualifies as consideration for an exempt supply under s. 2 of Part VI of Schedule V. ...

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