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13 March 1996 GST/HST Interpretation 11650-9[11] - Notional Input Tax Credits When a Person Trades a Used Vehicle as Partial Payment Towards the Lease of a New Vehicle

The following is our understanding of the facts for our consideration: • A consumer (the "lessee") arranges with a XXXXX automobile dealership (the "dealership") located in XXXXX to lease a new vehicle from XXXXX leasing (the "lessor"). ... The supply of the leased vehicle to the lessee is subject to tax on the full consideration notwithstanding the trade-in amount and the outstanding loan. ...

1 September 1997 GST/HST Interpretation 1997-09-01 - Section 231(1) of the Excise Tax Act

Among these requirements, ss. 231(1) of the ETA requires a supply to have been made and "that it is established that the consideration and tax" for that particular supply "have become in whole or in part a bad debt. ... In our view, this would not constitute a bad debt as the consideration and tax were paid by the recipients. ...

12 February 1999 GST/HST Interpretation HQR0001399 - Entitlements to Notional ITCs on Customer Equity From Trade-in Allowance

The consideration for that supply would be the value of the option i.e. the difference between the value of the vehicle and the cost of the buy out option. ... The consideration for this supply would be the buy-out amount. ($XXXXX[)] We have requested that the XXXXX ruling be revoked. ...

3 April 2000 GST/HST Interpretation 25507 - Errors in Publications and Information in EARL

Therefore, if the value of discounts received by a member is in excess of 30% of the value of the membership fee, the discounts will be significant in relation to the consideration for the membership. ... Therefore, if the value of discounts received by a member is 30% or greater than the membership fee, the discounts will be significant in relation to the consideration for the membership. ...

20 January 2000 GST/HST Interpretation 13403 - Bets and Games of Chance

Paragraph 187(c) of the ETA essentially deems the amount bet to equal the consideration for the supply of the service plus the GST and any taxes imposed under an Act of the legislature of any province. Subsection 165(1) of the ETA requires every recipient of a taxable supply made in Canada to pay tax at the rate of 7% on the value of consideration for the supply. ...

25 March 2002 GST/HST Interpretation 39617 - INTERPRETATION LETTER Professional Fees Paid by Government

Pursuant to the definition of "recipient" under subsection 123(1) of the ETA, where consideration for a supply is payable under an agreement, the "recipient" is the person who is liable under that agreement to pay the consideration. ...

30 June 2003 GST/HST Ruling 46184 - Supply of Promotional [Activities With Respect to the Business of Selling Food for Human Consumption]

The value of the consideration for the Product supplied together with the XXXXX will be either the same or marginally different than the consideration for the Product alone. 9. ...

29 March 2004 GST/HST Interpretation 50367 - Method to be Used in Calculating GST on Automobile Operating Expense Benefits

With respect to a taxable benefit that is or would, if the individual were an employee of the registrant and no reimbursements were paid, be required under paragraph 6(1)(k) or (l) of the ITA to be included in the individual's income, clause 173(1)(d)(vi)(A) of the ETA provides that for purposes of determining the net tax of the registrant, the tax calculated on the total consideration for an automobile operating expense benefit is deemed to be equal to the prescribed percentage of the total consideration. ...

25 April 2023 GST/HST Ruling 202403 - Eligibility for employer to claim ITCs on amounts related to investment management services for pooled funds of an insurer -- summary under Subsection 169(1)

CRA noted that there was insufficient information to determine whether the deduction of the IMFs represented the payment of charges by the pooled funds (viewed as segregated funds that were deemed to be separate trusts by s. 131) to the Insurer (in which event such charges would be subject to GST’HST pursuant to s. 131(1)(c)(i)), or whether the IMFs were merely an element in computing the unit value of the pooled funds, so that they were not consideration for any supply. However, under either interpretation, the Employer has not acquired investment management services under the Policies, nor paid GST/HST on the value of the consideration for such services, so that no input tax credits were available to it. ...

Nondisclosure Statement of Taxpayer

"] Signature: Printed Name: Position: Date: Notarized by Signature: Printed Name: Position: Date: 1 As defined in paragraph 7(a) of Article XXVI of the Canada –US Income Tax Convention (1980), the term "concerned person" means the presenter of a case to a competent authority for consideration under Article XXVI and all other persons, if any, whose tax liability to either Canada or the United States may be directly affected by the mutual agreement arising from that consideration. ...

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