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GST/HST Interpretation

8 January 2003 GST/HST Interpretation 43463 - Payments Made to Clergy, Church Organists and Soloist/Musicians

For your information, GST/HST does not apply to a donation where the donation is not consideration for a supply. If a donor receives something of value, the amount of the donation could be considered consideration for a supply. A gift at common law is considered a voluntary transfer of property without consideration. ...
GST/HST Interpretation

19 July 2023 GST/HST Interpretation 241308 - Application of GST to profit sharing amounts paid by an insurance broker to its parent company

It is a question of fact whether a supply, or supplies, was made by Holdco1 to BrokerCo and whether the payments received by Holdco1 are consideration for those supplies. ... Based on the limited information provided, it is not clear whether Holdco1 made a supply or supplies to BrokerCo for which the payments by BrokerCo were consideration. ... For example, management services may be supplied by the parent company to its subsidiary, for which consideration is paid. ...
GST/HST Interpretation

21 July 2023 GST/HST Interpretation 241678 - Application of GST to profit sharing amounts paid by an insurance broker to its parent company

It is a question of fact whether a supply, or supplies, was made by Holdco1 to BrokerCo and whether the payments received by Holdco1 are consideration for those supplies. ... Based on the limited information provided, it is not clear whether Holdco1 made a supply or supplies to BrokerCo for which the payments by BrokerCo were consideration. ... For example, management services may be supplied by the parent company to its subsidiary, for which consideration is paid. ...
Archived CRA website

ARCHIVED - Sale of Accounts Receivable

That portion of the sale price of the business that is the consideration for the accounts receivable is required to be set out in the election which the vendor and purchaser must execute pursuant to subsection 22(2). ... The amount that is stated in the election to be the consideration for the accounts receivable is final for tax purposes as far as the vendor and purchaser are concerned and cannot later be altered. ... If the agreement for the sale of the business does not specify what part of the total consideration is for the accounts receivable, a reasonable allocation must be made between accounts receivable and other assets included in the sale. ...
Current CRA website

Input Tax Credits Related to Dental Practices

Under the arrangement, a dentist who was a GST/HST registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances. ... A property or service is generally acquired for consumption or use in the course of a registrant’s commercial activities based on the extent to which the property or service is acquired for the purpose of making taxable supplies for consideration. ... An ITC must generally be apportioned where the property or service is acquired, imported or brought into a participating province for consumption or use, directly or indirectly, for the purpose of a dentist making both taxable supplies for consideration and exempt supplies. ...
Current CRA website

Application of the GST/HST to Credit Card Surcharges

A credit card surcharge is consideration strictly for the merchant’s acceptance of the use of a credit card as a payment method. Therefore, if a fee is, in whole or in part, consideration for some other service (such as a web or telephone service) or for the use of property (such as an online payment platform), the fee is not a credit card surcharge. ... In the case of a credit card surcharge, it will generally be treated as consideration for a separate supply of a financial service where it is shown and charged separately from the consideration for the property or service purchased with the use of the credit card and from all other fees or charges that may be payable by the customer. ...
Current CRA website

ETSL43 - Imposition of the air travellers security charge

For GST/HST purposes, the amount of the security charge is included in the consideration for the supply of the air transportation service. As such, where the supply of the service, other than a zero-rated supply, is made in a participating province, the total consideration for the supply, which includes the security charge, is subject to HST at 15%. Where the supply is made in a non-participating province, the total consideration for the supply, including the security charge, is subject to GST at 7% providing the supply is not zero-rated. ...
Old website (cra-arc.gc.ca)

Policy commentary CPC-025, Expenses incurred by volunteers

Definitions Amount of advantage: The total value of all property, services, compensation or other benefits to which the donor of a property, or a person not dealing at arm's length with the donor, is entitled as partial consideration for, or in gratitude for, the gift. ... To determine whether there is a gift, certain factors are taken into consideration, including: whether the expenses are incurred voluntarily or whether the volunteer was compelled to assume them For example, prior to agreeing to work on behalf of a charity, the individual voluntarily agrees to incur the hardships and costs associated with the work. The payment of the expenses would not constitute a gift if the volunteer is somehow compelled to assume them. whether the consideration accruing to the volunteer negates donative intent (that is, intention to give) For example, where a volunteer agrees to assume travel costs to work abroad for the charity, and then takes the opportunity to take a three-week vacation at the end or beginning of the work term. ...
Old website (cra-arc.gc.ca)

Tutoring or Instructing in Courses Approved for Credit by a School Authority

Ruling Given The consideration paid for the supply of Level II ballet to the student from Springfield Private School will be exempt of tax, since it is a mandatory prerequisite for the Level III ballet class. Also, the consideration charged for Level III ballet to the student who is eligible to receive a school credit from Springfield Private School will be exempt of tax. ... Furthermore, the consideration charged for the supply of lessons to the other dance school students who are not eligible to receive a credit will be subject to tax, even if they are in the same dance class as the Springfield student. ...
Old website (cra-arc.gc.ca)

Tax Status of a Natural Resource Lease Payment 'Expense'

The lease payment is consideration for a supply of the right to explore for or exploit a mineral deposit and the supply is deemed not to be a supply and any consideration paid or due, in respect of such a right is deemed not to be consideration for the right pursuant to subsection 162(1) of the Act. ...

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