Search - consideration
Results 24421 - 24430 of 29070 for consideration
Ruling
2023 Ruling 2022-0954211R3 - Estate Freeze and Corporate Attribution
With respect to a dividend deemed to have been paid by Aco on a redemption, acquisition or cancellation of the Aco Pref 3 Shares to which subsection 84(2) or 84(3) applies, the terms and conditions of the Aco Pref 3 Shares do not specify an amount in accordance with the requirements in subsection 191(4); c) for greater certainty, the Proposed Transactions contained in Paragraphs 28 to 30 will form part of any series of transactions or events implemented to avoid, reduce, or defer the tax consequences, described in subsection 104(4), to the First Trust on its 21st anniversary; and d) nothing in this letter should be construed as confirmation, express or implied, that, for the purposes of any of the Rulings given above, any adjustment to the FMV of the properties transferred or the redemption amount of the shares issued as consideration, whether pursuant to a price adjustment clause or otherwise, will be effective retroactively to the time of the transfer and issuance of shares. ...
Old website (cra-arc.gc.ca)
Transfer of Property to a Corporation Under Section 85
Forms T2057 and T2058 require you to disclose the fair market value of both the property disposed of and of the non-share consideration received. ... CONSIDERATION RECEIVED 8. Under section 85, the consideration that the transferor receives for the property transferred to the corporation has to include at least one share (or fraction of a share) of the capital stock of that corporation for the election to be valid. ... You should consider this when you determine the amount of consideration that has to be taken back to ensure that paragraph 85(1)(e.2) does not apply. ...
Scraped CRA Website
Transfer of Property to a Corporation Under Section 85
Forms T2057 and T2058 require you to disclose the fair market value of both the property disposed of and of the non-share consideration received. ... CONSIDERATION RECEIVED 8. Under section 85, the consideration that the transferor receives for the property transferred to the corporation has to include at least one share (or fraction of a share) of the capital stock of that corporation for the election to be valid. ... You should consider this when you determine the amount of consideration that has to be taken back to ensure that paragraph 85(1)(e.2) does not apply. ...
Current CRA website
Transfer of Property to a Corporation Under Section 85
Forms T2057 and T2058 require you to disclose the fair market value of both the property disposed of and of the non-share consideration received. ... CONSIDERATION RECEIVED 8. Under section 85, the consideration that the transferor receives for the property transferred to the corporation has to include at least one share (or fraction of a share) of the capital stock of that corporation for the election to be valid. ... You should consider this when you determine the amount of consideration that has to be taken back to ensure that paragraph 85(1)(e.2) does not apply. ...
GST/HST Ruling
14 February 2019 GST/HST Ruling 159878 - Refund of recaptured input tax credits (RITCs) on electricity charge types
The GA would therefore be treated as consideration for electricity and would be subject to RITC recapture provisions. ... The charge would therefore be treated as consideration for electricity and would be subject to RITC recapture provisions. ... The Debt Retirement Credit is not subject to HST as it is not a consideration for a supply.” ...
GST/HST Interpretation
17 August 1995 GST/HST Interpretation 11848-7 11846-3(LFR) - Tax Treatment of Services Provided to Victims of Crime
Are the payments made by XXXXX to XXXXX under Agreement I consideration for a supply? ... Are the payments made by XXXXX to XXXXX under Agreement II covering the period October 25, 1993 to April 1994 consideration for a supply? ... As such, it must be established whether the payments made are consideration for any supply which may be provided under Agreement I. ...
Current CRA website
Transfer of Property to a Corporation Under Section 85
Forms T2057 and T2058 require you to disclose the fair market value of both the property disposed of and of the non-share consideration received. ... CONSIDERATION RECEIVED 8. Under section 85, the consideration that the transferor receives for the property transferred to the corporation has to include at least one share (or fraction of a share) of the capital stock of that corporation for the election to be valid. ... You should consider this when you determine the amount of consideration that has to be taken back to ensure that paragraph 85(1)(e.2) does not apply. ...
Administrative Policy summary
10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Subsection 169(1)
10 February 2017 GST/HST Ruling 162056- Application of the GST/HST to an investment transaction-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) the purchase of an IP royalty gives rise to non-creditable GST/HST to the investor A Canadian registrant (Investor) enters into an agreement with a Canadian corporation (Corporation 1) under which it pays lump sums in consideration for the right to receive monthly royalties calculated as a percentage of intellectual property (IP) related revenue streams of Corporation 1. CRA ruled that the lump sums so paid are consideration for the taxable supply to Investor of intangible personal property (the right to the royalty payments). ...
Administrative Policy summary
10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Commercial Activity
10 February 2017 GST/HST Ruling 162056- Application of the GST/HST to an investment transaction-- summary under Commercial Activity Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Commercial Activity receipt of royalty not considertion for a taxable supply A Canadian registrant (Investor) enters into an agreement with a Canadian corporation (Corporation 1) under which it pays lump sums in consideration for the right to receive monthly royalties calculated as a percentage of intellectual property (IP) related revenue streams of Corporation 1. ... After ruling that the lump sums so paid are consideration for the taxable supply to Investor of intangible personal property (the right to the royalty payments), CRA went on to find that when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...
12 July 2023 GST/HST Ruling 174441 - and GST/HST INTERPRETATION - Application of GST/HST on funds raised through crowdfunding -- summary under Section 133
12 July 2023 GST/HST Ruling 174441- and GST/HST INTERPRETATION- Application of GST/HST on funds raised through crowdfunding-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 s. 133 effectively deemed advance payments to be consideration for a taxable supply A Canadian corporate registrant (“X”) raises money to fund a project through a crowdfunding website from supporters around the world. ... CRA indicated that pursuant to s. 133, “the tax applies to any advance payment or part payment of the consideration for a supply even if, at the time payment is made, property has not in fact been transferred.” ...