Search - consideration | Page 2479

27 November 2013 GST/HST Interpretation 152148 - New GST/HST rules on deemed supplies of property and services to pension entities -- summary under Subsection 172.1(5)

., the person liable to pay the consideration under the agreement for the supply) have been paid for out of trust assets because of the following situations, the CRA generally considers the payment made by the plan trust to be consideration for a supply of property or services made by the employer to the plan trust: * the plan trust paid the third party supplier directly, * the employer invoiced the plan trust for the costs of the inputs, and/or * the plan trust reimbursed the employer. ...

27 July 2021 GST/HST Interpretation 197267a - Allocation to a general partner -- summary under Subsection 272.1(1)

27 July 2021 GST/HST Interpretation 197267a- Allocation to a general partner-- summary under Subsection 272.1(1) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(1) draws to GP disproportionate to partnership capital is indicative of the receipt by it of such draws as consideration for services In commenting on the application of GST/HST to allocations of income, dividends and taxable capital gains allocations of income, dividends and taxable capital gains by a limited partnership to its general partner, CRA indicated that the general partner’s status as a person separate from the limited partnership means that the services rendered by it to the partnership “would be regarded for GST/HST purposes as a supply made to the partnership unless the deeming rule in subsection 272.1(1) applies.” Further,where the general partner provides services to the limited partnership and receives, as consideration, a distribution or allocation of income from the limited partnership that is “not in proportion” to its “percentage of equity interest in the capital of the partnership,” such distributions or allocations could be used to compensate the general partner for its services, such as management or administrative services, rendered to the limited partnership but it is not assigned a larger percentage of ownership interest in the limited partnership agreement. ...

25 May 2019 GST/HST Interpretation 185880 - Lease modification and renewal -- summary under Paragraph 142(1)(b)

Regarding the place of supply under this lease, CRA stated: Where consideration under a lease is payable on a periodic basis, subparagraph 136.1(1)(a) deems a separate supply of tangible personal property by way of lease to be made for each rental period. ... Each monthly rental payment under the lease agreement will be deemed to be consideration for a separate supply by way of lease made outside Canada, regardless of where the tangible personal property is subsequently located. ...

4 January 1995 GST/HST Interpretation 12005-5 - Paragraph 3(c) of Part VII of Schedule VI

I understand your question is as follows: Where a non-resident recipient of a supply of a passenger air transportation service tenders the consideration for that supply by placing a telephone call from the continental U.S.to a Canadian resident travel agent and giving a credit card number over the telephone, is that supply zero-rated by virtue of VI/VII/3(c) to the ETA provided, of course, that all of the other conditions in that paragraph are met? ... (c) the origin of the continuous journey is within the taxation area, but outside Canada, and the recipient of the supply tenders the consideration for the supply at a place outside Canada;.... ...

14 February 1997 GST/HST Interpretation HQR0000115 - GST Treatment of Payments Made Under

However, we cannot determine whether a specific payment made under XXXXX to XXXXX is consideration for a supply since the master agreement does not contemplate a particular project. ... We would like to point out that, in a case where payments made under a particular XXXXX subagreement are found not to be consideration for a supply, the ability for a XXXXX company to claim ITCs would be subject to subsection 141.01 of the Excise Tax Act as amended. ...

Registering a tax shelter

In addition, for applications made on or after March 29, 2012, the promoter may sell, issue, or accept consideration in respect of the tax shelter only for the calendar year designated by the Minister as being applicable to the identification number. ... As such, a promoter will need to obtain a new identification number for a tax shelter before selling, issuing or accepting consideration in respect of that tax shelter if the previous number is no longer valid. ...

P-159R-1 Meaning of the Phrase Reasonably Regarded as Incidental- (Revised first on April 1998 second on March 8, 1999)

However, if the supplier's objective is to provide several properties or services, then it is unlikely that the provision of one of the properties or services would be regarded as incidental to the provision of any other. 2) Is the value of consideration charged for a particular property or service provided together with other properties or services the same as, or only marginally different from, what the value of the consideration for the particular property or service would be if it were provided alone? ... The NPO supplies the two tickets together for a single consideration of $81.00. ... Therefore, the consideration charged for both tickets is only marginally different from the amount the NPO would charge if it was only supplying the ticket to the performance. ...

Meaning of the Phrase Reasonably Regarded as Incidental (Revised first on April 1998 second on March 8, 1999)

However, if the supplier's objective is to provide several properties or services, then it is unlikely that the provision of one of the properties or services would be regarded as incidental to the provision of any other. 2) Is the value of consideration charged for a particular property or service provided together with other properties or services the same as, or only marginally different from, what the value of the consideration for the particular property or service would be if it were provided alone? ... The NPO supplies the two tickets together for a single consideration of $81.00. ... Therefore, the consideration charged for both tickets is only marginally different from the amount the NPO would charge if it was only supplying the ticket to the performance. ...

29 January 2015 GST/HST Ruling 159222 - GST/HST on fees relating to a loan

The Acknowledgement Agreement also provides that in consideration of [CCo] providing financial assistance to [BCo] and for other valuable consideration, the receipt and sufficiency of which is acknowledged, [BCo] acknowledges and agrees that the Term Sheet and all terms and conditions thereof will continue in full force and effect notwithstanding the advance of the Loan by [CCo] and will govern the relationship between [CCo] and [BCo] in relation to the Loan as if the Term Sheet were a loan agreement entered into at the time of the advance of the Loan. 11. ... RULING GIVEN Based on the facts set out above, we rule that the interest and the Closing Fee are consideration for [CCo’s] supply of a financial service which is exempt under section 1 of Part VII of Schedule V to the ETA. ... The interest and the Closing Fee are consideration for this exempt supply. ...

29 January 2015 GST/HST Ruling 93176 - GST/HST on fees relating to a loan

The Acknowledgement Agreement also provides that in consideration of [CCo] providing financial assistance to [BCo] and for other valuable consideration, the receipt and sufficiency of which is acknowledged, [BCo] acknowledges and agrees that the Term Sheet and all terms and conditions thereof will continue in full force and effect notwithstanding the advance of the Loan by [CCo] and will govern the relationship between [CCo] and [BCo] in relation to the Loan as if the Term Sheet were a loan agreement entered into at the time of the advance of the Loan. 11. ... RULING GIVEN Based on the facts set out above, we rule that the Commitment Fee was consideration for [ACo]’s supply of a financial service which was exempt under section 1 of Part VII of Schedule V to the ETA. ... The Commitment Fee is consideration that was paid for this exempt supply. ...

You are here

Search - consideration

Filter by Type: