Search - consideration

In the first case, the the supply of recyclable scrap metal is made for consideration if the person acquiring it, namely a demolition company, attributes a value to that supply which it takes into account in the calculation of the price quoted for carrying out the demolition works with the consideration it received for its demolition work effectively being grossed up by this estimated amount. ... A similar gross up of consideration for reciprocal supplies might occur under ETA s. 153(1). ... Veronsaajien oikeudenvalvontayksikkö, [2019] EUECJ C-410/17 (10 January 2019) European Court of Justice (9 th Chamber) under ETA s. 123(1)- consideration. ...

24 June 2013- 3:40pm WHA- UK Supreme Court finds that an insurance claims handler for vehicle breakdowns did not receive a supply for VAT purposes of repair services from the mechanics Email this Content For British VAT purposes, an insurance claims processor was merely providing third party consideration rather than consideration for repair services received by it when it paid mechanics for repair work on cars that were insured under vehicle break-down insurance provided by an affiliated insurer.  ... Among other considerations, the drivers had direct implied contracts with the mechanics under which they authorized the repair work and agreed to cover any shortfall between the repair cost and the insurance cover. ...

17 September 2018- 11:18pm CRA confirms that it is possible to structure a P3 project so as to defer the applicability of GST/HST until revenues are ascertained Email this Content Typically, P3 project construction costs for a hospital, bridge etc. are intended for ITA purposes to be viewed as consideration for the grant of a concession or licence (a Class 14 property) by the public authority to the private operating company to enter onto the premises to operate it and earn a monthly operating fee (see e.g., 2006-0218781R3). On the ETA side, CRA instead views the consideration for the incurring of the construction costs as being included in the subsequent monthly amounts payable by the authority. Provided that the amount of such consideration is not yet ascertainable, GST/HST is not triggered (one month after substantial completion) under ETA s. 168(3)(c) on the value of the supply made to the public authority by virtue of the supply of the hospital etc. and is deferred under s. 168(6) until the monthly amounts become ascertainable. ...

., the distribution restriction in s. 74.4(4) was not complied with), the preferred shares received on the refreeze will be excluded consideration that do not reduce the “outstanding amount” (as determined under s. 74.4(3)) on which the deemed interest benefit is computed under s. 74.4(2). If the refrozen preferred shares are redeemed for cash consideration, that consideration will reduce the outstanding amount, but only to the extent of the fair market value of those shares. ...

10 August 2021- 1:55am CRA position accommodating extracting cash on an amalgamation may facilitate surplus stripping Email this Content 2018-0785921E5 and 2017-0696821E5 indicate that where there is a distribution of cash and shares to shareholders of predecessor corporations pursuant to an amalgamation, the conditions of s. 87(1)(c) will be met, while the receipt of the non-share consideration will preclude s. 87(4) from applying, so that such shareholders will realize a capital gain or loss based on the value of the shares and cash received from Amalco. This suggests that surplus of a corporation can be extracted on its amalgamation as cash or other non-share consideration. S. 84(2) risk can be minimized by continuing to operate the businesses of the predecessors and taking the non-share consideration as a note that is drawn down over time. ...

The CRA indicated that the monthly equipment rental fees paid by the merchant to DeviceCo were consideration for taxable supplies by DeviceCo. However, the fees paid by the merchant under the Service Agreement were regarded as consideration for the processing of credit and debit card payments within the payments network and, thus, as consideration for exempt supplies of financial services. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2012-04-27 17 April 2012 External T.I. 2011-0427411E5 F- Bien de remplacement-immobilisation admissible Income Tax Act- Section 14- Subsection 14(7) shares cannot be replacement property 17 April 2012 External T.I. 2012-0440931E5 F- Crédit d'impôt pour frais médicaux Income Tax Regulations- Regulation 5700- Section 5700- Paragraph 5700(i) motorized stationary bicycle did not qualify 2012-04-20 10 April 2012 External T.I. 2011-0428701E5 F- Lien de dépendance- commanditaire et SEC Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) limited partner at arm's length with LP if it has no management authority 10 April 2012 Internal T.I. 2011-0430291I7 F- Montant d'aide versé par la SAAQ à un conjoint Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit automobile insurance payments received for care of injured spouse were non-taxable 3 April 2012 External T.I. 2011-0426341E5 F- Catégories 29 et 43 Income Tax Regulations- Schedules- Schedule II- Class 29 scrap metal shearing device and container for sliced metal described in Class 29 2011-04-01 23 March 2011 Internal T.I. 2010-0389081I7 F- Disposition of a resource property Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (a) proceeds included full (undiscounted) deferred cash proceeds, but might exclude share consideration (with volatile market price) until issued Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) deferred share consideration potentially not recognized until issuance Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) full undiscounted amount of future cash consideration to be included as an amount receivable Income Tax Act- Section 66.2- Subsection 66.2(5)- cumulative Canadian development expense- Element F proceeds from mineral claims sale included undiscounted deferred cash proceeds, but might exclude share consideration until issued; purchaser’s CEE obligation excluded ...