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30 May 2025 External T.I. 2025-1050201E5 - Part XX Reporting Obligations -- summary under Consideration

30 May 2025 External T.I. 2025-1050201E5- Part XX Reporting Obligations-- summary under Consideration Summary Under Tax Topics- Income Tax Act- Section 282- Subsection 282(1)- Consideration reporting platform operators may be required to infer the consideration paid to platform vendors from the dollar value of their orders The operator (the “Operator”) of a proprietary digital platform (the “Platform”), who was also an equipment manufacturer, allowed independent vendors (the “Vendors”) to list their goods for sale on the Platform to select customers. ... CRA then indicated that, generally, if a particular seller was determined by a reporting platform operator to be a reportable seller, CRA expected the operator to report the information set out in s. 292, including the total consideration paid or credited during each quarter of the reportable period. The CRA reiterated that if the reporting platform operator knew the total value of orders placed with the seller, this could make the seller's consideration "reasonably knowable" to the reporting platform operator as per the definition of consideration. ...

24 January 2019 External T.I. 2018-0773301E5 - Paragraph 69(1)(c) and Nominal Consideration -- summary under Paragraph 69(1)(c)

24 January 2019 External T.I. 2018-0773301E5- Paragraph 69(1)(c) and Nominal Consideration-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) a transfer structured as a sales agreement for nominal consideration may qualify as a gift $1 consideration is specified in the legal documentation for a gift of property by a parent to a child solely to ensure the agreement is legally binding. Would s. 69(1)(c) apply, notwithstanding that nominal consideration of $1 would be paid? ... 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. ...

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. ...

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