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GST/HST Ruling

20 January 2000 GST/HST Ruling 8104/HQR0001710 - Application of the GST/HST to Counselling Services

Explanation What must be determined is whether the payment from XXXXX is consideration for the supply provided by XXXXX or whether it is a grant. ... Therefore, XXXXX is viewed as contracting out its responsibilities and, based on TIB-067, the payment made to your company is consideration for a supply. Section 165 of the Excise Tax Act (ETA) 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 Interpretation

5 June 2001 GST/HST Interpretation 34836 - Application of the GST/HST to ABM Services

We consider this fee to be a rental fee and therefore, it is consideration for a taxable supply. The fact that the consideration is calculated on the number of ABM transactions is irrelevant. ... As for the situation where the ABM owner pays a portion of the interchange fee to the merchant, the fee is also taxable because it is not paid as consideration for the supply of an exempt financial service as explained above. ...
GST/HST Interpretation

6 December 2002 GST/HST Interpretation 43472 - Application of the GST/HST to Prepaid Funeral Arrangements

The contributions may be based on an estimate of the consideration that will be payable for the funeral services and the eventual GST/HST that will apply. GST/HST will apply on the value of the consideration to be paid to the funeral home under the prepaid funeral arrangement at the time it is paid or becomes due to the funeral home whichever is earlier. The value of the consideration and tax payable to the funeral home under the agreement generally approximates the amount of the contributions and any interest that has accumulated in the trust. ...
GST/HST Interpretation

6 December 2002 GST/HST Interpretation 40859 - Application of the GST/HST to Prepaid Funeral Arrangements

The contributions may be based on an estimate of the consideration that will be payable for the funeral services and the eventual GST/HST that will apply. GST/HST will apply on the value of the consideration to be paid to the funeral home under the prepaid funeral arrangement at the time it is paid or becomes due to the funeral home whichever is earlier. The value of the consideration and tax payable to the funeral home under the agreement generally approximates the amount of the contributions and any interest that has accumulated in the trust. ...
GST/HST Interpretation

6 December 2002 GST/HST Interpretation 43468 - Application of the GST/HST to Prepaid Funeral Arrangements

The contributions may be based on an estimate of the consideration that will be payable for the funeral services and the eventual GST/HST that will apply. GST/HST will apply on the value of the consideration to be paid to the funeral home under the prepaid funeral arrangement at the time it is paid or becomes due to the funeral home whichever is earlier. The value of the consideration and tax payable to the funeral home under the agreement generally approximates the amount of the contributions and any interest that has accumulated in the trust. ...
GST/HST Interpretation

6 December 2002 GST/HST Interpretation 43470 - Application of the GST/HST to Prepaid Funeral Arrangements

The contributions may be based on an estimate of the consideration that will be payable for the funeral services and the eventual GST/HST that will apply. GST/HST will apply on the value of the consideration to be paid to the funeral home under the prepaid funeral arrangement at the time it is paid or becomes due to the funeral home whichever is earlier. The value of the consideration and tax payable to the funeral home under the agreement generally approximates the amount of the contributions and any interest that has accumulated in the trust. ...
GST/HST Interpretation

6 December 2002 GST/HST Interpretation 43471 - Application of the GST/HST to Prepaid Funeral Arrangements

The contributions may be based on an estimate of the consideration that will be payable for the funeral services and the eventual GST/HST that will apply. GST/HST will apply on the value of the consideration to be paid to the funeral home under the prepaid funeral arrangement at the time it is paid or becomes due to the funeral home whichever is earlier. The value of the consideration and tax payable to the funeral home under the agreement generally approximates the amount of the contributions and any interest that has accumulated in the trust. ...
GST/HST Interpretation

17 October 2002 GST/HST Interpretation 41067 - Exempt Status of Spread Payable to Issuers of MBS

The interpretation stated that the spread received by the Lender/Issuer as described in the Guide is consideration for the provision of a "financial service" and is exempt from the GST. Interpretation Given Based on a review of the Guide, it is our opinion that the fee received by the Issuer, i.e., the "spread", is consideration for the provision of a financial service and is exempt from the GST/HST. ... Therefore, since the administrative services are supplied by a person at risk, i.e., the Issuer, the spread received by the Issuer as consideration for the servicing of the mortgage pool is consideration for a financial service and is exempt from GST/HST. ...
GST/HST Interpretation

23 October 2002 GST/HST Interpretation 41949 - Industrial/Commercial Condominium Corporations

The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. However, a person ceases to be a small supplier at any time in a calendar quarter if the total value of the consideration that becomes due, or is paid without becoming due, in that quarter for world-wide taxable supplies made by the person, or an associate of the person at the beginning of the calendar quarter, exceeds $30,000 or, if the person is a public service body, $50,000. 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 or $50,000 small supplier threshold. ...
GST/HST Interpretation

31 July 2002 GST/HST Interpretation 37094 - Tax Status of Mortgaging Services

Since the amounts left over are not in respect of the consideration for the purchase, it is our view they are in respect of a separate consideration for the supply of the administrative services. Accordingly, sections 138 and 139 of the Act are not applicable as the single consideration criteria contained in those sections has not been met. These amounts paid by the Trust to the seller are consideration for a taxable supply of administrative services. ...

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