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GST/HST Interpretation

10 June 2002 GST/HST Interpretation 35594 - Hotel Cancellation Fees

Under the legislation, the tax in respect of the supply becomes payable on the earlier of the day the consideration for the supply is paid or becomes due. The one night's accommodation charged to the individual's credit card account is the consideration payable for the supply of real property made to the individual by the hotel. As the XXXXX and the XXXXX are located in XXXXX XXXXX, the HST is, therefore, applicable on the consideration payable for the supply (i.e., one night's accommodation). ...
GST/HST Interpretation

19 February 2003 GST/HST Interpretation 41177 - Application of GST/HST to Additional Amount Received from Client

With respect to the additional amount paid by XXXXX to the partnership, it appears that the amount is paid as additional consideration for the services provided by the partnership. ... In other words, it appears that XXXXX has determined that the partnership's services rendered in the past are deserving of additional consideration. ... Consequently, the partnership is required to account for the GST in respect of the additional consideration. ...
GST/HST Interpretation

19 December 2003 GST/HST Interpretation 45870 - Application of the GST to Charges Under a Contract for Electricity

Interpretation Requested How would CRA determine whether the charges for reserving capacity are for a distinct supply of reserving capacity or part of the consideration for the supply of electricity? ... Therefore, during any review of a contract, consideration would be given to the industry's perception that the division of charges between capacity charges and energy charges is just a method of determining the consideration payable for the electricity. ... As a result, the consideration for the supply of reserving capacity would be taxable at the rate of 7% where the supply is in a non-participating province, and the rate of 15% where the supply is made in a participating province (Nova Scotia, New Brunswick, or Newfoundland and Labrador). ...
Current CRA website

Penalties

False or misleading information Failing to file a return Misrepresentation of a tax matter by a third party Failing to provide the tax shelter identification number Providing an incorrect tax shelter identification number False or misleading information Under subsection 237.1(7.4), every person: who files false or misleading information in Form T5001, Application for Tax Shelter Identification Number and Undertaking to Keep Books and Records who as a principal or as an agent sells, issues or accepts consideration in respect of a tax shelter before the Minister of National Revenue has issued an identification number is liable to a penalty that is the greater of: $500 25% of the greater of: the total of all consideration received or receivable in respect of the tax shelter before the correct information is filed with the minister, or the identification number is issued the total of all amounts stated or represented to be the value of property a person who acquires or invests in the tax shelter could donate to a qualified donee, if the tax shelter is a gifting arrangement and consideration has been received or is receivable before the correct information is filed with the minister, or the identification number is issued Failing to file a return Under subsection 237.1(7.5), every person who fails to: file an information return in response to a demand by the CRA report in the return: the name, address and either the social insurance number or business number of each participant who acquires or otherwise invests in the tax shelter in the year an amount paid by a participant in respect of the tax shelter is liable to a penalty that is 25% of the greater of: the total of all consideration received or receivable in respect of a tax shelter from a particular person in respect of whom the required information had not been reported at or before the time that the demand was issued or the return was filed if the tax shelter is a gifting arrangement, the total of all amounts stated or represented to be the value of property that the particular person could donate to a qualified donee Misrepresentation of a tax matter by a third party The Income Tax Act provides for third-party civil penalties to deter third parties from making false statements or omissions in relation to income tax or GST/HST matters. ...
Current CRA website

Capital gains realized on gifts of certain capital property

You may be entitled to an inclusion rate of zero on any capital gain realized on such gifts if you donate: a share of the capital stock of a mutual fund corporation a unit of a mutual fund trust an interest in a related segregated fund trust a prescribed debt obligation a share, debt obligation, or right listed on a designated stock exchange certified ecologically sensitive land including a covenant or an easement to which land is subject or, in the case of land in Quebec, a personal servitude where certain conditions are met or real servitude gifted to a qualified donee other than a private foundation a real servitude or under certain conditions, a personal servitude (for more details, see Ecologically gifts) The inclusion rate of zero is extended to any capital gain realized on the exchange of shares of the capital stock of a corporation for securities listed in the first five bullets above that are then donated if the capital stock shares meet all of the following conditions: at the time they were issued and at the time of disposition, the shares included a condition allowing the holder to exchange them for the securities the securities are the only consideration received on the exchange the securities are donated within 30 days of the exchange If the exchanged property is a partnership interest (other than prescribed interests in a partnership), the capital gain will generally be whichever of the following amounts is less: the capital gain otherwise determined the amount, if any, by which the cost to the donor of the exchanged interests, plus any contributions to partnership capital by the donor, exceeds the ACB of those interests (determined without reference to distributions of partnership profits or capital) If you donate property to a qualified donee that is, at the time of the donation, included in a flow-through share (FTS) class of property, you are deemed to have a capital gain from the disposition of another capital property. ... Granting of options to a qualified donee You cannot claim a gift related to an option to acquire a property that is granted to a qualified donee until the qualified donee either exercises or sells the option: Where the option is: A) exercised by the qualified donee, the amount of the gift is generally equal to: the FMV of the underlying property, minus any consideration that you receive from the qualified donee for the property and the option B) sold by the qualified donee, the amount of the gift is equal to whichever is less: the result from A) above the result of: the FMV of any consideration (other than a non-qualifying security of any person) received by the qualified donee for the option, minus any consideration that you receive from the qualified donee for the option Completing your Form T1170 and Schedule 3 Complete Form T1170, Capital Gains on Gifts of Certain Capital Property for all donations of these properties. ...
Current CRA website

What information is shared

In particular, available financial account identifiers should be provided where the seller resides in a reportable jurisdiction or an immovable property with respect to which relevant services are being provided by a seller is located in a reportable jurisdiction The name of the holder of the financial account to which the consideration is paid or credited (if different from the name of the seller and if available to the platform operator), along with any other identifying information in respect of that account holder available to the platform operator Activity information Total consideration paid or credited to the seller in the reporting period in respect of relevant activities (broken down by calendar quarter) and the number of such relevant activities What is consideration Consideration is compensation in any form that is paid or credited to a seller in connection with relevant activities, the amount of which is known or reasonably knowable by the platform operator. ...
Current CRA website

T4A-RCA slip – Retirement Compensation Arrangement (RCA) trust

Box 20 – Other amounts Report the amount if the RCA trust: Disposed of property for consideration less than the fair market value (FMV) of the property Acquired property for consideration greater than the FMV of the property Permitted the RCA trust's property to be used for consideration less than the FMV of such use Under subsection 56(11), the amount to include in box 20 is the difference between the consideration and the FMV. ...
Current CRA website

Increases to Air Travellers Security Charge Rates Effective May 1, 2024

The ATSC is payable by a person acquiring an air transportation service that includes a chargeable emplanement at the time any consideration is paid or payable for the service. Where no consideration is paid or payable, the ATSC is payable at the time the ticket is issued for the service. ... The new ATSC rates will apply to air transportation services that include a chargeable emplanement on or after May 1, 2024, if any consideration is paid on or after that date. ...
Technical Interpretation - Internal

23 July 2007 Internal T.I. 2007-0228601I7 F - Redemption of U.S. Denominated Shares

In consideration, it issues to Parentco preferred shares of another class denominated in Canadian dollars (the "Canadian Preferred Shares"). ...
Technical Interpretation - Internal

25 February 2014 Internal T.I. 2013-0475161I7 - Whether USCo has a PE in Canada

In determining the existence of commercial coherence, factors that would be relevant include: 1) whether the projects would, in the absence of tax planning considerations, have been concluded pursuant to a single contract; 2) whether the nature of the work involved under different projects is the same; and 3) whether the same individuals are providing the services under the different projects. ...

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