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13 October 1994 External T.I. 9425475 - 7(1.5) APPLICATION WHIT NON SHARE CONSIDERATION -- summary under Subsection 7(1.5)

13 October 1994 External T.I. 9425475- 7(1.5) APPLICATION WHIT NON SHARE CONSIDERATION-- summary under Subsection 7(1.5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.5) RC intimated that it would be prepared to apply its position that s. 85.1(1) applies to some transfers where non-share consideration also is received, to s. 7(1.5). ...

13 May 2014 External T.I. 2014-0525491E5 - Emigration to Poland - Various tax considerations -- summary under Article 18

13 May 2014 External T.I. 2014-0525491E5- Emigration to Poland- Various tax considerations-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 lump sum RRSP commutation not eligible for reduced withholding under Polish Treaty As "pension" was not defined in the Canada-Poland Treaty, s. 5(a) of the Income Tax Conventions Interpretation Act applied, so that all of the RPP, RRSP, OAS, CPP and QPP payments made to the Taxpayer (a former Canadian who became a Polish resident) were to be considered "pensions" for the purposes of the Treaty. ...

1 May 1998 GST/HST Interpretation 1998-05-01[2] - XXXXX Energy Performance Contracts Additional Consideration for the Supply Subsequent Reductions in Consideration

1 May 1998 GST/HST Interpretation 1998-05-01[2]- XXXXX Energy Performance Contracts Additional Consideration for the Supply Subsequent Reductions in Consideration Unedited CRA Tags ETA 232(1), 232(2) XXXXX Douglas Wood A/Rulings Officer General Operations Unit General Operations and Border Issues Division Subject: XXXXX Energy Performance Contracts Additional Consideration for the Supply Subsequent Reductions in Consideration This memorandum is in response to your e-mail of September 4, 1997, and your subsequent telephone calls, where you requested our views on amounts refunded or credited by XXXXX to its customers, as part of energy performance contracts. ... The amount subsequently refunded or credited to the customer would be regarded as a reduction in consideration, to which subsection 232(2) of the ETA would apply. ... Consequently, a refund or credit to the customer, as provided for under paragraph 23.6 of the XXXXX, would be regarded as a subsequent reduction in consideration, under subsection 232(2) of the ETA. ...

Large construction projects engage a litany of tax considerations

6 October 2015- 11:20pm Large construction projects engage a litany of tax considerations Email this Content Tax considerations arising under a major construction project include: Significant deferral benefits can arise from the choice of the Project LP’s year end given that the stub period accrual rules do not bite if the previous year was not yet profitable. CRA has accommodated (e.g., in 2006-0218781R3) treating the Project LP’s construction costs as consideration for a right to access the construction site, so that such costs can be amortized as a Class 14 asset. ... PST considerations in B.C. engage the distinction between fixtures and tangible personal property. ...

CRA indicates that a transfer structured as a sales agreement for nominal consideration may qualify as a gift

25 February 2019- 12:11am CRA indicates that a transfer structured as a sales agreement for nominal consideration may qualify as a gift Email this Content A parent gifted property to a child. A correspondent seemed to assume that this gift was legally required to be effected through an agreement specifying nominal consideration (of $1), with such nominal consideration actually being paid, rather than the gift being effected through a deed of gift. ... For example, if the agreement governing the transfer provides for consideration of $1 merely to ensure that the agreement is legally binding, the CRA may consider the transfer to be a gift. … If it is determined that the transfer of property was a sale for inadequate consideration rather than a gift, paragraph 69(1)(c) would not apply. ...

MEO – European Court of Justice finds that an early termination fee was consideration for the contracted service

The ECJ found that this lump sum was taxable “consideration” received by MEO for its services on ordinary principles for VAT purposes, stating: [I]t must be held that the consideration for the amount paid by the customer to MEO is constituted by the customer’s right to benefit from the fulfilment, by MEO, of the obligations under the services contract, even if the customer does not wish to avail himself or cannot avail himself of that right for a reason attributable to him. In Canada, the distinction between consideration received by the supplier of services pursuant to the services contract, and compensation received by it for termination of the contract, is relevant because the latter amount is deemed by ETA s. 182 to be inclusive of GST/HST. ... Autoridade Tributária e Aduaneira, ECLI:EU:C:2018:942 (ECJ (5th Chamber)) under ETA s. 123(1) – consideration. ...

CanLII – Tax Court of Canada finds that law society funding received by CanLII was consideration for taxable supplies of its services

Lamarre ACJ found that CanLII instead was making a taxable supply for which the amounts collected from the Federation were the consideration. She first noted that the ETA definition of “consideration” included any amount that is payable for a supply “by operation of law.” ... V, s. 10 and s. 123(1)- consideration. ...

CRA finalizes its Memorandum on when transfer payments are taxable consideration

20 April 2023- 11:48pm CRA finalizes its Memorandum on when transfer payments are taxable consideration Email this Content CRA has finalized its GST/HST Memorandum on the issue of when a governmental or other transfer payment is consideration for a supply, with only very minor changes from the previous draft version. CRA indicates that if there is a direct link between a supply made by the grantee and a transfer payment, the transfer payment is consideration for that supply, and provides various guidelines to assist in that determination. ... Summary of GST/HST Memorandum 18-4 “Determining Whether a Transfer Payment is Consideration For a Supply” June 2022 under ETA s. 123(1) – consideration. ...

CRA treats a trust distribution of a life insurance policy to a beneficiary as being made for FMV consideration equal to the part of the beneficiary’s capital or income interest that is satisfied

CRA considers that a dividend-in-kind of a life insurance policy by a corporation (Aco) to its shareholder is made for no consideration for purposes of s. 148(7)(a)(ii)(B), so that on the dividend-in-kind, the policy was deemed to be disposed of for the greatest of its ACB, CSV and the (nil) consideration received, or $150. However, where a trust transfers the policy to its beneficiary, the beneficiary (Xco) is regarded as giving consideration for the transfer that is all or any part of the beneficiary's income or capital interest, as applicable. Here, it would be reasonable to consider that such consideration had an FMV of $250. ...

CRA treats a trust distribution of a life insurance policy to a beneficiary as made for FMV consideration equal to the part of the beneficiary’s capital or income interest that is satisfied

The dividend-in-kind of the life insurance policy by a corporation (Aco) to its shareholder is made for no consideration for purposes of s. 148(7)(a)(ii)(B), so that on the dividend-in-kind, the policy is deemed to be disposed of for the greatest of its ACB, CSV and the (nil) consideration received- or $150. However, where a trust transfers the policy to its beneficiary, the beneficiary (Xco) is regarded as giving consideration for the transfer that is all or any part of the beneficiary's income or capital interest in the trust, as applicable. Here, it would be reasonable to consider that such consideration had an FMV of $250. ...

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