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Current CRA website
Place of Supply in a Province – Real Property
Under section 136.2, the provision of the part of the real property that is situated in the particular participating province and the provision of the part of the real property that is situated in another province or outside Canada are each deemed to be a separate taxable supply made for separate consideration equal to the portion of the total consideration for all the property that is reasonably attributable to each part of the real property.  ... Because the real property is situated in both Ontario and Quebec, the provision of each part of the real property is deemed to be a separate supply for consideration equal to the portion of the total consideration for all the property that is reasonably attributable to the part that is situated in each province.  ... Since the properties are situated in more than one province, the supply of the real property is deemed to be two separate supplies made for separate consideration.  ...
Current CRA website
Trade Unions and Similar Employee Associations
As such, the annual membership fee payable by each fund member is not deemed to be consideration for an exempt supply under section 189. 6.  ... Under section 189, the union is deemed to be making exempt supplies to its members, and the dues paid to the union by its members—via employer deduction—are deemed to be consideration for those exempt supplies. 8.  ... The amounts retained by the employer from the individual’s paycheques and paid to the trade union under these types of circumstances constitute consideration for exempt supplies under paragraph 189(b) and are not subject to GST/HST.  ...
Current CRA website
Other GST Returns (GST 500-2-6)
Pursuant to subsection 218(1) of the Act, every recipient of an imported taxable supply is liable for the GST equal to seven per cent of the value of the consideration for the imported taxable supply. 6.  ... The GST is payable by the recipient on the earlier of the day on which the consideration is paid and the day on which the consideration for the supply becomes due. 10.  ... An instalment payable under a contract in respect of which subsection 118(3) or 118(4) of the Act applies is excluded from "consideration" for the purpose of this section. 23.  ...
Old website (cra-arc.gc.ca)
New Home Purchase Agreements in Alberta
In the case of a transaction of this nature straddling the date of implementation of the GST, the GST will generally be payable on the full consideration for the complex (notwithstanding that part of the consideration was with respect to the real property transferred prior to 1991) where the parties agree that it is a supply of a residential complex such that the FST new housing rebate is available and the GST new housing rebate may be transferred from the purchaser to the builder.  ... If the FST new housing rebate is claimed and/or the GST new housing rebate is transferred to the builder in accordance with section 254, the GST will be payable on the full consideration for the residential complex (notwithstanding that part of the consideration may have been with respect to the real property transferred prior to 1991).  ...
Old website (cra-arc.gc.ca)
Compliance Bulletin
Acquisition of property for more than fair market value (FMV) or disposition of property for less than FMV Subsection 146(9) provides that, where a trust governed by a RRSP disposes of property for less than the FMV of the property at the time of the disposition, or acquires property for a consideration greater than the FMV of the property at the time of the acquisition, the difference between the FMV and the consideration is included in computing the income of the annuitant under the plan. Subsection 146.3(4) provides that, where a trust governed by a RRIF disposes of property for less than the FMV of the property at the time of the disposition, or acquires property for a consideration greater than the FMV of the property at the time of the acquisition, then two times the difference between the FMV and the consideration is included in computing the income of the taxpayer who is the annuitant under the fund.  ...
Current CRA website
New Home Purchase Agreements in Alberta
In the case of a transaction of this nature straddling the date of implementation of the GST, the GST will generally be payable on the full consideration for the complex (notwithstanding that part of the consideration was with respect to the real property transferred prior to 1991) where the parties agree that it is a supply of a residential complex such that the FST new housing rebate is available and the GST new housing rebate may be transferred from the purchaser to the builder.  ... If the FST new housing rebate is claimed and/or the GST new housing rebate is transferred to the builder in accordance with section 254, the GST will be payable on the full consideration for the residential complex (notwithstanding that part of the consideration may have been with respect to the real property transferred prior to 1991).  ...
GST/HST Interpretation
14 May 2019 GST/HST Interpretation 160444 - Membership fee
What did the supplier provide for the consideration received? 4. Is the recipient made aware of the elements (in detail) that are part of the package?  ... This is an amount which, although separately identified, appears to be part of the total consideration for the supply of the membership in the Club. The member is merely being advised how the total consideration for the membership is allocated.  ...
GST/HST Interpretation
17 December 2015 GST/HST Interpretation 153009 - […][Whether a zero-rated supply of a Financial Service to a non-resident shareholder]
[The submission] took paragraphs (n) through (t) of the definition of “financial service” into consideration and concluded that the supply being made was not excluded from the definition. […][The analysis] noted that paragraph (t) refers to a “prescribed service” and […] the corresponding Financial Services (GST/HST) Regulations (the Regulations).  ... Section 1 of Part IX of Schedule VI zero-rates a supply of a financial service (other than a supply that is included in section 2) made by a financial institution to a non-resident person, except where the service relates to (a) a debt that arises from (i) the deposit of funds in Canada, where the instrument issued as evidence of the deposit is a negotiable instrument, or (ii) the lending of money that is primarily for use in Canada; (b) a debt for all or part of the consideration for a supply of real property that is situated in Canada; (c) a debt for all or part of the consideration for a supply of personal property that is for use primarily in Canada; (d) a debt for all or part of the consideration for a supply of a service that is to be performed primarily in Canada; or (e) a financial instrument (other than an insurance policy or a precious metal) acquired, otherwise than directly from a non-resident issuer, by the financial institution acting as a principal.  ...
GST/HST Interpretation
21 December 2017 GST/HST Interpretation 164739 - – Taxable benefits and the section 156 election
As a result, the taxable supply of vehicles by way of lease from Corp A to Corp B are deemed to be made for no consideration.  ... Paragraph 170(1)(b) generally provides that in determining an ITC of a registrant, no amount shall be included in respect of the tax payable by the registrant in respect of a supply of property or a service that is acquired by the registrant at any time in or before a reporting period of the registrant exclusively for the personal consumption, use, or enjoyment (the “benefit”) in that period of a particular individual who was, is, or agrees to become an officer or employee of the registrant, or of another individual related to the particular individual, except where (i) the registrant makes a taxable supply of the property or service to the particular individual or the other individual for consideration that becomes due in that period and that is equal to the fair market value of the property or service at the time the consideration becomes due, or (ii) if no amount were payable by the particular individual for the benefit, no amount would be included under section 6 of the Income Tax Act in respect of the benefit in computing the income of the particular individual for the purposes of that Act.  ... When a valid section 156 election is in effect between two corporations, all taxable supplies made between those corporations, other than certain supplies set out in subsection 156(2.1), are deemed to have been made for no consideration.  ...
GST/HST Ruling
27 October 2020 GST/HST Ruling 189355 - […][Whether a subcontractor is an agent of a contractor]
RULING REQUESTED You would like to know whether [the subcontractor] acquired the […] permits as [the contractor’s] agent, in which case [the subcontractor] should not include the permit fees when it calculates HST on the amount of consideration it charges in respect of its supply of […] services to [the contractor], or as inputs into its supply to [the contractor], such that [the subcontractor] should include the permit fees when calculating HST on the amount of consideration it charges in respect of the supply. RULING GIVEN Based on the facts set out above, we rule that [the subcontractor] acquired the […] permits as inputs to its taxable supplies of […] services to [the contractor], such that the amount of the permit fees that [the subcontractor] charges to [the contractor] are included in the consideration for the supplies of the services on which HST applies.  ... As a result, [the subcontractor] is not acquiring the […] permits as an agent of [the contractor], and the amount of the fees incurred by [the subcontractor] to acquire the permits that it charges to [the contractor] are included in the consideration for its taxable supplies of the […] services made in [Province A] (the […] services are in relation to real property that is situated entirely in [Province A]) on which HST is calculated.  ...
