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8 June 2006 GST/HST Ruling 58290 - "Arranging for" a financial service

Therefore, A has not acquired the property or service for consumption, use or supply in the course of its commercial activities and it is not entitled to an input tax credit in respect of the tax paid on the consideration for the supply. However, since A acquired the property or service in its fiduciary capacity as the administrator for the benefit of the plan and fund, where A has paid for the supply and then B has subsequently reimbursed it for the amount, the reimbursement is not consideration for a supply and is not subject to GST/HST. ... To the extent A is engaged in commercial activities and the requirements under section 169 of the ETA are met, it will be entitled to claim input tax credits for the GST/HST paid or payable on the consideration for the supplies of the property and services. ...

4 January 2006 GST/HST Ruling 50286 - Application of the GST/HST to the purchases and supplies of the XXXXX

Newco and AB will enter into a construction contract wherein the consideration payable by AB for construction services rendered by Newco will be equal to approximately cost plus $XXXXX. ... This provision stipulates that a supply of property or a service that is made for no consideration or for consideration less than the fair market value of the property or service at the time the supply is made shall be deemed to be made for consideration of a value equal to the fair market value at that time provided the supplier and recipient of the supply are not dealing with each other at arm's length and the recipient of the supply is not a registrant who is acquiring the property or service for consumption, use or supply exclusively in the course of commercial activities of the recipient. ... Consequently, subsection 155(1) will apply if the supply of the Facility made by way of lease is made for no consideration or for consideration less than fair market value since XY is acquiring the Facility by way of lease for consumption, use or supply exclusively in the course of its exempt activities. ...

3 May 1995 GST/HST Interpretation 11895-6[1] - Tax Treatment of Public Transportation Services for the Physically Handicapped

XXXXX advised XXXXX that effective July 1, 1993 payments made by XXXXX in respect of these services are not consideration for a supply. ... OPINIONS REQUESTED 1) Are the payments made by XXXXX to XXXXX consideration for a supply under the Excise Tax Act (the Act)? ... OPINIONS GIVEN 1) It is our opinion that the payments made by XXXXX to XXXXX are consideration for the supply of services. ...

2 May 1995 GST/HST Interpretation 11895-6[2] - Application of GST to the Supply of Contract Services

XXXXX advised XXXXX that effective July 1, 1993 payments made by XXXXX in respect of these services are not consideration for a supply. ... Opinions Requested 1) Are the payments made by XXXXX to XXXXX consideration for a supply under the Excise Tax Act (the Act)? ... Opinions Given 1) It is our opinion that the payments made by XXXXX are consideration for the supply of services. ...

7 August 1998 GST/HST Ruling HQR0001080 - Application of the GST/HST to Supplies of Literature Made by a Registered Charity

Accordingly, allocations that represent reimbursements for the purchase and distribution of such supplies will be viewed as consideration for taxable supplies. Another possibility is that at least a portion of the payments from the Branches to the National may be consideration for the supply of management or administration services. ... Generally this exemption applies where the consideration for the supply does not exceed the direct cost of the supply. ...

26 February 2001 GST/HST Ruling 31464 - Entitlement by to Claim Input Tax Credits

Ruling Given Based on the facts set out above, we rule that XXXXX is making taxable supplies of midwifery services for no consideration. The payments provided to XXXXX by the XXXXX through the XXXXX are grants and are not consideration for the supply of midwifery services. ... Subsection 141.01(1.2) provides that if a registrant receives an amount that is not consideration for a supply from a government and that assistance can reasonably be considered to be provided for the purpose of funding an activity that involves the making of taxable supplies for no consideration, then the amount is deemed to be consideration for those taxable supplies. ...

21 August 2002 GST/HST Interpretation 39650 - Clarifications for Policy Concerning Travel Allowances for Indian Bands

If it takes 10 hours to repair the machine, the total consideration is $750 (6 x $10 + $150 allowance). ... The consideration is $60 per hour to provide the repair service plus expenses for transportation, meals and accommodation. If it takes 10 hours to repair the machine and the expenses were $289, the total consideration is $889 (10 x $60 + $289). ...

6 December 2024 GST/HST Interpretation 247167 - Supplies of uninsured activities by a medical practitioner

A block fee arrangement is the right to obtain a predetermined set of uninsured services in consideration for a flat fee. ... Therefore, the consideration under a block fee arrangement that is not covered by the [provincial health care plan], for the right of exchanging by email with a medical practitioner is subject to the GST/HST. ... In general, block fees arrangements and the consideration for uninsured services that are not qualifying health care supplies will need to be taken into consideration for the purposes of calculating the $30,000 threshold. ...

General Information (T5008)

For the purposes of Regulation 230, it includes all consideration, such as cash, debt obligations, shares, and so on. that is paid or payable to the transferor. ... In certain circumstances, the Income Tax Act considers that a property has been disposed of, even though no real compensation in the form of money or other consideration has been received. ... In the case of a deemed disposition, ownership of the property is not transferred for money or other consideration. ...

Appendices

Programs* 3 3 0 100 Total 83 72 11 87 * All program branches share accountability for these commitments- Appeals, ACB, Customs, and PPB Legend: Appeals- Appeals Branch ACB- Assessment and Collections Branch ITB- Information Technology Branch FAB- Finance and Administration Branch HRB- Human Resources Branch PPB- Policy and Planning Branch CAEB- Corporate Audit and Evaluation Branch Appendix 3: Status of 2001-2004 action plan commitments Goal 1: Prepare managers to contribute to SD Items Descriptions Completed In progress Not started Dropped 1.1 Objective: Demonstrate leadership and commitment to SD 1.1.1 Recognize SD as a corporate value X 1.1.2 Finalize the SD policy X 1.1.3 Fully integrate SD into the business planning and reporting process to support the horizontal nature of SD X 1.1.4 Link our commitment to SD with appropriate messages in the CCRA Leadership Program X 1.2 Objective: Increase practice of balanced decision-making related to programs, policies, and operations 1.2.1 Develop and implement guidelines for integrating SD into the development of business plans and proposals to ensure that all aspects of SD are considered X 1.3 Objective: Raise the level of SD awareness; increase SD skills and knowledge 1.3.1 Develop/implement a SD learning strategy for management X 1.3.2 Review ongoing learning programs to identify SD awareness/training opportunities X 1.3.3 Provide managers with guidance material to support environmental stewardship and compliance X 1.4 Objective: Measure, monitor, and promote continuous improvement for SD results 1.4.1 Integrate SD considerations into key corporate management tools: 1.4.1.1 balanced scorecard 1.4.1.2 risk management policy 1.4.1.3 quality service initiative X 1.4.2 Perform periodic reviews of SDS implementation and report findings to senior management in conjunction with regular audit program X 1.4.3 Conduct a management review of the SDS 2001- 2004 and update the SDS for 2004-2007 X 1.4.4 Close significant gaps in the management and control system for the SDS in particular, documenting procedures and implementing a process for non-conformance and corrective action X Goal 2: Enable employees to contribute to SD Items Descriptions Completed In progress Not started Dropped 2.1 Objective: demonstrate leadership and commitment to SD 2.1.1 Create opportunities for employees to pledge commitment to SD X 2.2 Objective: Raise the level of SD awareness; increase SD skills and knowledge 2.2.1 Create and maintain opportunity for employees to share SD success stories, initiatives, and comments X 2.2.2 Provide employees with guidance material to help support environmental stewardship initiatives X 2.2.3 Encourage participation in CRA-endorsed initiatives, such as the annual commuter challenge (ongoing) X Goal 3: Green operations to contribute to SD Items Descriptions Completed In progress Not started Dropped 3.1 Objective: Demonstrate leadership and commitment to SD by continuing to develop and implement an environmental management system consistent with the ISO 14001 standard 3.1.1 Finalize CRA Environmental Policy X 3.1.2 Develop environmental management programs for all identified environment aspects: Procurement Paper Solid waste management Land use management Energy Water quality and conservation Fleet Ozone depleting substances X 3.1.3 Fully implement all elements of a performance measurement framework for: 3.1.3.1 Storage tanks 3.1.3.2 ODS management X 3.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 3.2.1 Develop and pilot the use of SD guidelines for integrating SD into the development of operational resource proposals to ensure all aspects of SD are considered X 3.3 Objective: Measure, monitor, and promote continuous improvement 3.3.1 Develop/refine appropriate administrative systems to track performance on environmental and SD commitments X 3.4 Objective: Enhance or develop new partnerships to support shared SD objectives 3.4.1 Continue participation in interdepartmental committees, working groups and initiatives related to the environment and SD (ongoing) X 3.5 Objective: Meet or exceed federal environmental legislation and regulations and implement best management practices for environmental issues: 3.5.1 Procurement 3.5.1.1 Review/assess current Material Management Certification courses for green content X 3.5.1.2 Pilot green procurement training program with Headquarters' procurement officers; share results of pilot with others X 3.5.1.3 Introduce environmental specifications into National Individual Standing Offers X 3.5.1.4 Increase the number of clauses that give consideration to SD-green procurement into the contractual process, including selection criteria for Requests for Proposals (RFPs) X 3.5.2 Paper 3.5.2.1 Develop/revise procedures and standards to help reduce dependence on paper in internal operations: 3.5.2.1.1 Issue electronic document management standards X 3.5.2.1.2 Increase availability of forms, policies, and procedures on the Intranet (ongoing) X 3.5.2.1.3 Enhance and administer the protocol for submissions to the Agency Management Committee and Board of Management to help reduce paper use X 3.5.2.1.4 Implement an initiative to submit documents electronically to the National Archives/National Library X 3.5.3 Waste management 3.5.3.1 Divert an average of 50% solid waste from landfill in priority custodial facilities X 3.5.3.2 Implement best management practices for waste management including recycling at remaining custodial facilities X 3.5.3.3 Divert an average of 70% solid waste from landfill in priority leased facilities X 3.5.3.4 Integrate the requirement for contractor to provide waste reduction plans into all major construction, renovation and demolition projects in custodial and leased facilities (carry-over commitment) X 3.5.3.5 Implement best practices and initiatives related to the disposal (recycling/reusing) of obsolete or surplus goods: 3.5.3.5.1 Develop national disposal guidelines for publications no longer required 3.5.3.5.2 Review existing disposal guidelines for opportunities to integrate SD considerations 3.5.3.5.3 Assess/implement surplus uniform donations program X 3.5.4 Energy 3.5.4.1 Develop and communicate best management practices for energy efficiency X 3.5.4.2 Continue to participate in federal climate change initiatives (to be done in conjunction with the federal climate change initiative) X 3.5.4.3 Negotiate the inclusion of energy efficiency measures at leased facilities X 3.5.4.4 Implement energy and water conservation measures associated with the Federal Buildings Initiative (or other programs) when an energy assessment has demonstrated that it is cost-effective X 3.5.4.5 Incorporate energy efficiency measures, including the use of renewable energy alternatives, into major construction and renovation projects where feasible and cost effective with life-cycle payback X 3.5.5 Land use management Compliance assurance related to CEAA 3.5.5.1 Strengthen protocol to monitor/report on follow-up activities recommended by environmental assessment screening reports X Capital construction/renovation 3.5.5.2 Implement measures to "green" new capital construction projects (ongoing) X Compliance assurance with the Canadian Environmental Protection Act (CEPA): Storage tank regulation 3.5.5.3 Strengthen protocol to demonstrate compliance with CEPA's Federal Storage Tanks Regulation X Compliance with federal policy on contaminated sites 3.5.5.4 Strengthen protocol to demonstrate compliance with the federal policies for contaminated sites X 3.5.5.5 Assess and remediate contaminated sites consistent with best practices (ongoing) X 3.5.6 Ozone depleting substances (ODS) management 3.5.6.1 Manage inventories to reduce releases of ODS consistent with the Federal Halocarbon Regulations X 3.5.6.2 Implement management plan to convert / replace ODS inventories with alternative substances or technologies X 3.5.7 Fleet management 3.5.7.1 Reduce fleet emissions by increasing the number of alternative fuel vehicles in compliance with the Alternative Transportation Fuels Act (ATF) X 3.5.7.2 Continue reporting on compliance with the Alternative Fuels Act (annually) X 3.5.7.3 Co-ordinate fleet awareness training as opportunities arise through the government initiatives on climate change X 3.5.8 Water management 3.5.8.1 Strengthen protocol for water quality management X 3.5.8.2 Develop and communicate best management practices for water conservation X 3.5.8.3 Incorporate water conservation measures into major construction and renovation projects where feasible X 3.5.9 Hazardous substances management 3.5.9.1 Review hazardous materials management X 3.5.9.2 Develop strategies and action plans as required X 3.5.9.3 Strengthen protocol for Workplace Hazardous Materials Information System (WHMIS) X 3.5.10 Environmental emergencies 3.5.10.1 Strengthen protocol for environmental emergencies X Goal 4: Enhance programs to contribute to SD Items Descriptions Completed In progress Not started Dropped 4.1 Objective: Demonstrate leadership and commitment to SD 4.1.1 Explore ways to communicate our commitment to SD to clients, partners, and stakeholders and encourage their support X 4.1.2 Implement specific initiatives that help encourage compliance with Canadian laws, protect the health and safety of Canadians, and promote eco-efficiency: 4.1.2.1 Administrative Monetary Penalty System (AMPS) 4.1.2.2 Migrant health program 4.1.2.3 Pre-approval permit programs X 4.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 4.2.1 Integrate SD into program management tools and practices: 4.2.1.1 negotiate inclusion of SD considerations in the Service Management Framework arrangements with provinces and territories to articulate CRA's commitment to SD 4.2.1.2 Incorporate SD in the CRA Business Development Strategy 4.2.1.3 Integrate environmental considerations into the Customs Self-Assessment initiative to reduce waiting times, trucks idling at borders X 4.2.2 Integrate consideration of SD into development of new program proposals and initiatives X 4.3 Objective: Measure, monitor, and promote continuous improvement 4.3.1 Explore ways to measure and report performance results of programs on all three aspects of SD X 4.4 Objective: Enhance or develop new partnerships to support shared SD objectives 4.4.1 Incorporate SD considerations into consultations with partners: 4.4.1.1.1 E-commerce conference 4.4.1.1.2 Memoranda of Understanding (MOU) with partners 4.4.1.1.3 Voluntary Sector Joint Initiative Action Plan 4.4.1.1.4 Annual consultation process X 4.4.2 Continue to work with other government departments in support of sustainable development: 4.4.2.1 Identify health and safety issues for trade and border compliance plan X 4.4.2.2 Harmonize customs procedures and electronic systems in support of Asia Pacific Economic Cooperation and Free Trade Area of the Americas trade facilitation initiatives X 4.5 Objective: Implement best management practices for environmental issues in program delivery: paper consumption procurement waste 4.5.1 Advance the use of electronic service delivery options and streamline paper-based transactions with the aim of reducing the use of paper: 4.5.1.1 Implement electronic service delivery options (ongoing) X 4.5.1.2 Implement the Correspondence Issue Management System (due March 31, 2005) X 4.5.1.3 Play lead role in global e-commerce industry by promoting e-filing and telefiling X 4.5.1.4 Negotiating the filing of RRSP listing to reduce need for paper filing X 4.5.1.5 Develop e-filing of objections through the Internet X 4.5.1.6 Develop Web-based training on blueprint initiatives X 4.5.2.7 Review forms and publications and expand use of Web site for distribution of information to clients X 4.5.1.8 Convert archival information onto software X 4.5.1.9 Reduce paper in charities tax package (T3010) by approximately 33% X Appendix 4: List of abbreviations AMPS Administrative Monetary Penalty System ACB Assessment and Collections Branch APEC Asian- Pacific Economic Coorperation AWICS Agency-wide Classification System BFTSO Burnaby-Fraser Tax Services Office Appeals Appeals Branch CAEB Corporate Audit and Evaluation Branch CAS Corporate Administration System CBSA Canada Border Services Agency CEAA Canadian Environmental Assessment Agency CEW Canadian Environment Week CIDA Canadian International Development Agency CIMS Correspondence Issue Management System CPB Corporate Business Plan CPE Customs Port of Entry EDM Electronic Document Management EMP Environmental Management Program EMS Environmental Management System EPPD Executive Personnel Programs Directorate ESS Employer Self-Service FAB Finance and Administration Branch FAST Free and Secure Trade FIHO Federal House In Order Initiative FPSCD Financial Policy Systems and Control Division HRB Human Resources Branch IMD Information Management Directorate MMD Materiel Management Directorate MSDS Material Safety Data Sheets MSS Manager Self-Service ITB Information Technology Branch OECD Organisation for Economic Co-operation and Development OPI Office of Primary Interest PATA Pacific Association of Tax Administrations PPB Policy and Planning Branch PWGSC Public Works and Government Services Canada PWRA Potable Water Risk Assessment RARD Revenue Accounting and Reporting Division SD Sustainable development SDS Sustainable development strategy SDGO Sustainable Development Government Operations SIMA Special Import Measures Act SMF Service management framework TPSD Telecommunications and Program Support Directorate TC Tax centre TSO Tax services office VSI Voluntary Sector Initiative WHMIS Workplace Hazardous Materials Information Systems WCO World Customs Organization Previous page Page details 2017-06-22 ...

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