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26 March 1996 GST/HST Interpretation 11650-3[4] - Entitlement to a Notional Input Tax Credit

Accordingly, the provision will allow the registrant to claim an NITC equal to 7/107ths of the consideration. ... There is no indication in the agreement that the XXXXX agreed to sell and that the corporation agreed to buy the property for consideration. ... Subsection 123(1) of the ETA defines recipient to be the person who is liable to pay the consideration under any agreement for the supply and, where there is no agreement, the person who is otherwise liable to pay the consideration. ...

3 July 1997 GST/HST Interpretation HQR0000412 - Tax Status of Out-of-Court Settlement,

If it is a taxable supply, is the payment consideration for that supply? ... It would be more reasonable to consider that the supply made in 19 XXXXX was made for no consideration and that the payment made under the Agreement was not made as consideration for the earlier supply. ...

12 March 1999 GST/HST Ruling HQR0001289 - Application of the GST/HST to Membership Fees

Section 6 of Part VI of Schedule V of the ETA provides an exemption where the consideration for a supply is equal to or less than its direct cost. ... Generally, the "licensing" of a trademark to members would be regarded as the supply of intangible personal property, and since there is no apparent exemption for it, the consideration for the supply would be subject to tax. ... GST/HST is not applicable to the receiptable donations to the XXXXX that you have described, since gifts at law are not viewed as consideration for a supply. ...

25 June 2002 GST/HST Interpretation 32284 - Application of GST/HST to a Dating Service and a Social Club

Consideration (Under the ETA, "consideration" includes any amount that is payable for a supply by operation of law. ... Pursuant to section 159 of the ETA, when the consideration for a supply is expressed in foreign currency (e.g., US dollars), the value of the consideration shall be calculated based on the value of the foreign currency in Canadian currency. ... GST/HST becomes payable on the earliest of the day on which consideration is paid or becomes due. ...

2005 Ruling 2005-0112571R3 F - Butterfly Transaction - Papillon

(c) qu'il soit fait mention dans les caractéristiques des actions de catégorie "F" qu'un "montant indiqué" aux fins du paragraphe 191(4) sera désigné par résolution des administrateurs lors de leur émission, sans excéder la JVM de la considération reçue lors de leur émission. ... Il sera fait mention dans les caractéristiques des actions de catégorie "F" qu'un "montant indiqué" aux fins du paragraphe 191(4) sera désigné par résolution des administrateurs lors de leur émission, sans excéder la JVM de la considération reçue lors de leur émission. ...

30 March 1993 Income Tax Severed Letter 9235566 - Motion Picture Films—Capital Cost Allowance

The foregoing factors will be taken into consideration when making a determination. ... At the beginning of year 3, the Canadian corporation would acquire the limited partnership interest from the limited partner at fair market value and would give common shares as consideration. ...

2003 Ruling 2003-0034773 - Test Wind Turbine-XXXXXXXXXX

Prior to undertaking the proposed transactions detailed below, X Co will transfer at fair market value all of its rights, titles and interests to the property relating to the Project to Opco, including the PPA, for consideration consisting solely of XXXXXXXXXX common shares of Opco. ... No Class A share of Opco that has been issued would be cancelled as a result of the occurrence of any Act of Termination and no amount in respect of consideration paid for a share so issued would be returned to the investor. 33. ...

2001 Ruling 2000-0057853 - EMPLOYEE BONUS PLAN

A Co has entered into management services arrangements with B Co and other subsidiaries of A Co which provide for charges to B Co and such subsidiaries in favour of A Co in consideration for A Co making available the services of its employees. ... When A Co or B Co receives a payment in kind rather than in cash upon the disposition of all or a portion of a Qualifying Investment, no amount will be added to the Participants' Principal Accounts until such consideration has been realized in cash, at which time amounts will be credited to the Participants' Principal Accounts in the same manner as on the disposition of a Qualifying Investment for cash proceeds. 39. ...

5 June 1992 Income Tax Severed Letter 9129915 - Banks' securities transactions — income or capital

Economic considerations dictated the sale in 1951. His Honour held that the profit on sale was made in the carrying on of the company's business and was assessable as a profit according to the ordinary usages and concepts of mankind. ... One important consideration in buying shares was that they should immediately- or within a reasonable period- produce a dividend yield of 4% or better. ...

14 September 1992 Income Tax Severed Letter 2M01980 - Income Earned or Realized

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information This example illustrates why losses of corporations in a corporate group must be included in the computation of consolidated income earned or realized.5 The same result would obtain if, sometime before the relevant time, A Co had sold the shares of C Co to B Co for nominal consideration. ... Investment Tax Credit Depreciable Property A corporation that has acquired a property, or made an expenditure, the specified percentage of which is included in its investment tax credit as defined in subsection 127(9) may claim a deduction from its tax otherwise payable under Part I of the Act as permitted in subsection 127(5), or it may be deemed by subsection 127.1(1) to have paid an amount on account of its tax under Part I of the Act, which amount is deemed to have been deducted under subsection 127(5). 1) Subsection 13(7.1) A incorporates A Co and subscribes for common shares for consideration of $100. ...

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