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TCC

Tétrault v. The Queen, 2004 TCC 332 (Informal Procedure)

Tétrault did not work in consideration of a wage and the sums that Mr. ... But what was that consideration? Can it be said that the paying of household expenses is consideration for the transfers? ... The mere right to be the beneficiary of this obligation does not constitute a particular consideration. ...
Old website (cra-arc.gc.ca)

Calculating Input Tax Credits

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...
Current CRA website

Calculating Input Tax Credits

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...
Current CRA website

Calculating Input Tax Credits

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...
Old website (cra-arc.gc.ca)

TPM-13 - Referrals to the Transfer Pricing Review Committee

This will be the taxpayer’s only opportunity to submit additional information for the TPRC’s consideration. ... Recharacterization referrals In situations involving the application of paragraphs 247(2)(b) and (d), the TPRC uses a three-stage approach: Initial consideration Consideration of a formal referral Final consideration 1. ... The taxpayer should be encouraged to bring forward facts for consideration during the review. 2. ...
Current CRA website

TPM-13

This will be the taxpayer's only opportunity to submit additional information for the TPRC's consideration. ... Recharacterization referrals In situations involving the application of paragraphs 247(2)(b) and (d), the TPRC uses a three-stage approach: Initial consideration Consideration of a formal referral Final consideration 1. ... The taxpayer should be encouraged to bring forward facts for consideration during the review. 2. ...
Old website (cra-arc.gc.ca)

GST/HST and place of supply rules

Lease intervals– Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Therefore, the supply of the intangible personal property is made in Ontario and subject to HST at a rate of 13% Rule 3 If Rule 1 and 2 do not apply, the supply is made in a given province under the following conditions: Consideration of $300 or less If the value of the consideration for the supply of the IPP is $300 or less, the supply is made in a province if: the supply is made through a permanent establishment of the supplier located in the province in the presence of an individual who is the recipient, or through a vending machine situated in the province the IPP can be used in the province Address in Canada obtained If the preceding rule does not deem the supply to be made in a province, the supply may be deemed to be made in a participating province if the supplier obtains an address of the recipient in the province in the normal course of business and if the IPP can be used in the province. ... See examples- Rule 3- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...
TCC

Harvard Properties Inc. v. The King, 2024 TCC 139

It does not address the tax considerations of a sale of the shopping centre, nor the differing results or considerations of a share sale versus a sale of the shopping centre itself. ... Doner, and the tax consequences, considerations and risks to the Abacus proposal. ... The other consideration received by each co-owner was its share of the Deposits. ...
TCC

British Columbia Transit v. The Queen, [2006] GSTC 103, 2006 TCC 437

Consideration [45]     Was there or was there not consideration for the lease? ... "Nominal consideration" and a "nominal sum" in the law appear to me, as terms of art, to refer to a sum or consideration which can be mentioned as consideration but is not necessarily paid. ... The comparison, if indeed a comparison is necessary, should be between the actual consideration and a fair market value (FMV) consideration. ...
TCC

Republic National Bank of New York v. The Queen, docket 96-2492-GST-G

The remainder of the $14,011,901.42 is apparently interest owed to Yarkon. [90] For the purposes of section 183, the value of consideration is defined by subsection 153(1), which states: 153. (1) Value of consideration-- Subject to this Division, the value of the consideration, or any part thereof, for a supply shall, for the purposes of this Part, be deemed to be equal to (a) where the consideration or that part is expressed in money, the amount of the money; and (b) where the consideration or that part is other than money, the fair market value of the consideration or that part at the time the supply was made. [91] A common definition used for consideration is that given by Lush J. in Currie v. ... Where the consideration for a supply, or a portion thereof, is other than money, the value of that consideration is equal to the fair market value of the consideration at the time the supply was made. ... The respondent simply argued that such amounts did not constitute consideration. ...

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