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GST/HST Interpretation

16 August 1996 GST/HST Interpretation 11650-9[9] - Proposed Amendment to Section 153 - The "Trade-in Approach"

Selling Price $28,000.00 Less Trade-in   20,000.00 Adjusted Consideration     8,000.00 GST on Purchase (Adjusted Consideration x 7%)        560.00 Note: The conditions of proposed subsection 153(4) have been met therefore the consideration for the supply of the new vehicle is reduced by the amount credited for the trade-in. ... Therefore, the lessor will credit $3,000 for the leasehold interest against the value of the consideration of the new automobile when calculating the monthly lease payment. ... The conditions of proposed subsection 153(4) have been met therefore the consideration for the supply of the new vehicle is reduced by the amount credited for the trade-in. ...
GST/HST Interpretation

18 November 1999 GST/HST Interpretation HQR0001976 - Time of Liability for GST/HST

As such, the consideration payable in respect of the taxable supply of the manual or the subscription for updates to the manual is not deemed to become due on a particular day under the provisions of subsection 152(1). Subsection 168(1) of the ETA provides that GST/HST 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 the consideration for the supply becomes due. ... Therefore, in accordance with subsection 168(1) of the ETA, the GST/HST is payable on the day that the consideration is paid as the consideration does not become due on an earlier date in both situations. ...
GST/HST Interpretation

1 June 1999 GST/HST Interpretation HQR0001668 - Re: GST on Award Settlement

Based on the information provided, we are of the view that the net amount in issue is consideration for a taxable supply. ... Under subsection 152(1) of the Act, the consideration for a supply is generally deemed to have "become due" on the day on which the supplier first issues an invoice in respect of the supply for that consideration. ... Based on our understanding of the relevant documents however, it is not entirely clear to us whether all of the consideration for those services became due prior to May 1991 within the meaning of subsection 152(1) of the Act. ...
GST/HST Interpretation

31 August 2000 GST/HST Interpretation 24995 - Tax Status of Payment Received Under Land Withdrawal Agreement

The compensation paid to XXXXX by the oil and gas company is consideration for this supply. ... " If the lump-sum payment to XXXXX is for such a right then it is deemed not to be consideration and thus not subject to GST. ...
GST/HST Ruling

4 July 2000 GST/HST Ruling 8392 - Application of the GST/HST to Licence Fees

In our letter of July 7, 1999, to the Board we indicated that the $1/XXXXX was consideration for an exempt supply of a licence in accordance with paragraph 20(c) of Part VI of Schedule V to the Excise Tax Act (ETA). 11. ... The buyer (i.e. the agent of the Board) deducts from the consideration payable to the producer, the licence fee and remits the fee to the Board on behalf of the Producer. ... As in the above scenario, buyers are required to deduct from the consideration payable to the producers in respect of the supply of the XXXXX, a licence fee. ...
GST/HST Interpretation

1 November 2001 GST/HST Interpretation 32278 - Boarding of Bison in Canada

Where a barter transaction occurs, the value of the consideration for the supply made by one person is normally the fair market value of the property and/or services received from the other person. 3. ... In particular, pursuant to 164.1(2) of the Act, where, in the course of operating a feedlot that is a farming business within the meaning of the Income Tax Act, a person makes a supply of a service and the consideration for the supply (in this subsection referred to as the "total charge") includes a particular amount that is identified in the invoice or agreement in writing for the supply as being attributable to feed, (a) the provision of the feed shall be deemed to be a supply separate from the supply of the service and not to be incidental to the provision of any other property or service; (b) the portion, not exceeding 90%, of the total charge that is reasonably attributable to the feed and is included in the particular amount shall be deemed to be the consideration for the supply of the feed; and (c) the difference between the total charge and the consideration for the supply of the feed shall be deemed to be the consideration for the supply of the service. 5. ... Section 165 of Act requires every recipient of a taxable supply made in Canada to pay to Her Majesty the GST/HST on the value of the consideration for the supply except where the supply is zero-rated. ...
GST/HST Ruling

18 October 2002 GST/HST Ruling 35779 - Tax Status of Transcription Services

In this case, the person ceases to be a small supplier immediately before the consideration becomes due or is paid for the particular taxable supply that puts the person over the $30,000 threshold. Both of these calculations exclude consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ... Please note that if the total consideration paid by XXXXX to XXXXX XXXXX, including the portion of the consideration that XXXXX XXXXX will pay to the medical transcribers, for the transcription services performed in whole or in part in Canada by XXXXX exceeds $30,000 Canadian in any four consecutive calendar quarters or in any one calendar quarter, XXXXX will be required to register for GST/HST purposes. ...
Archived CRA website

ARCHIVED - Sale of Inventory

For a taxpayer on the cash basis of reporting income, the consideration received for inventory thus sold is included in computing income for the year or years in which it is received and the corresponding costs of that inventory are deductible in the year they are paid. ¶ 2. ... Where one person has sold business inventory to another person and the amount of the consideration paid or payable by the purchaser was in part consideration for the inventory so sold and in part consideration for something else, the part of the amount that may reasonably be regarded as consideration for the inventory is deemed by section 68 to be both the proceeds of disposition of that inventory and the amount at which it was acquired by the purchaser. ... In the event the vendor and purchaser are not dealing at arm's length and the fair market value of the inventory sold is significantly more or less than the consideration paid therefor, paragraph 69(1)(a) or (b) will apply, requiring the portion of the total proceeds allocated to inventory to be based on fair market value. ...
GST/HST Interpretation

8 December 2009 GST/HST Interpretation 119345 - Application of the Transitional Rules for the HST in Ontario to Supplies Made by Golf Course Owners and Operators

An initiation fee may be consideration for a membership, which may or may not be a lifetime membership, or the initiation fee may be consideration for some other right. 6. We confirm that: (a) For any lifetime golf memberships sold after October 14, 2009 and before July 2010, where the consideration in full becomes due or is paid without having become due at that time, the Supplier would charge GST on 25% of the consideration and HST on 75% of the consideration. ... The service charges are likely additional consideration for the supply made by the Supplier. ...
GST/HST Interpretation

17 August 2020 GST/HST Interpretation 194307 - Eligibility for ITCs […] [by the Financial Institution] on inputs used by […][the subcontractors]

See the section of our analysis below entitled, “Consideration of arm’s length and fair market value” for further explanation. ... The procurative extent is the extent to which the input is acquired for the purpose of making taxable supplies for consideration or the extent to which it is acquired for purposes other than making taxable supplies for consideration. The operative extent is the extent to which the consumption or use of the input is for the purpose of making taxable supplies for consideration or the extent to which the consumption or use is for purposes other than making taxable supplies for consideration. ...

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