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Election for Nil Consideration
Election for Nil Consideration GST/HST memorandum 14.5 October 2012 Section 156 of the Excise Tax Act (the Act) provides an election that permits corporations and Canadian partnerships (as defined in that section), to treat certain taxable supplies between them as having been made for no consideration, if the requirements for the election are satisfied. ... NewCo and OpCo are not party to an election under section 150 and want to elect under section 156 so that the transfer of these operating assets to NewCo would be deemed to be made for no consideration. ... In this regard, subsection 141.01(7) ensures that any provision deeming a supply to be made for no consideration does not apply for the purposes of determining the extent to which inputs used in making the supply are acquired, imported, used or consumed by the person for the purpose of making taxable supplies for consideration in the course of an endeavour of the person. ...
Scraped CRA Website
Election for Nil Consideration
Election for Nil Consideration GST/HST memorandum 14.5 October 2012 Section 156 of the Excise Tax Act (the Act) provides an election that permits corporations and Canadian partnerships (as defined in that section), to treat certain taxable supplies between them as having been made for no consideration, if the requirements for the election are satisfied. ... NewCo and OpCo are not party to an election under section 150 and want to elect under section 156 so that the transfer of these operating assets to NewCo would be deemed to be made for no consideration. ... In this regard, subsection 141.01(7) ensures that any provision deeming a supply to be made for no consideration does not apply for the purposes of determining the extent to which inputs used in making the supply are acquired, imported, used or consumed by the person for the purpose of making taxable supplies for consideration in the course of an endeavour of the person. ...
Scraped CRA Website
P-222 Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of Excise Tax Act (ETA)
P-222 Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of Excise Tax Act (ETA) Notice to the reader Reference in this publication is made to supplies that are subject to the GST or the HST. ...
Scraped CRA Website
RC4616 Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes
RC4616 Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes Notice to the reader Under proposed changes, to be considered closely related for purposes of neither charging nor collecting the GST/HST on certain intercompany supplies in addition to meeting the conditions of the current test, a corporation or partnership must also hold and control 90 per cent or more of the votes in respect of every corporate matter of the subsidiary corporation (with limited exceptions). ...
Folio Summary
S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime -- summary under Income-Producing Purpose
If, as is frequently the case, such a loss is not reasonably incidental to the normal income-earning activities, considerations in determining deductibility in cases involving senior employees include: the extent of the senior employee's authority and control. ...
Folio Summary
S5-F1-C1 - Determining an Individual’s Residence Status -- summary under Article 4
The circumstances must be examined as a whole, but it is nevertheless obvious that considerations based on the personal acts of the individual must receive special attention. ...
Folio Summary
S5-F2-C1 - Foreign Tax Credit -- summary under Subparagraph 115(1)(a)(ii)
For the following particular types of business, the following factors (among others) should be given consideration: development and sale of real or immovable property – the place where the property is situated; merchandise trading – the place where the sales are habitually completed, but other factors, such as the location of the stock, the place of payment or the place of manufacture, are considered relevant in particular situations; transportation or shipping – the place of completion of the contract for carriage, and the places of shipment, transit and receipt; trading in intangible property, or for civil law incorporeal property (for example, stocks and bonds) – the place where the purchase or sale decisions are normally made; money lending – the place where the loan arrangement is in substance completed; personal or movable property rentals – the place where the property available for rental is normally located; real or immovable property rentals – the place where the property is situated; and service – the place where the services are performed. 1.54 Other factors which are also relevant, but generally given less weight than the factors listed above include, but are not limited to: the place where the contract for the sale of property or the provision of services is formed or entered into; the place where payment is received; the place where assets of the business are located; and the intent of the taxpayer to do business in the particular jurisdiction. 1.55 In the case of a single business comprised of more than one of the above-mentioned activities, each activity is considered separately for purposes of determining in which country or countries the business is carried on (this situation should not be confused with the situation in which the taxpayer has separate businesses—see Interpretation Bulletin IT-206R, Separate businesses). ...
GST/HST Ruling
12 September 2017 GST/HST Ruling 142842 - Whether the Global Adjustment is considered as part of the consideration payable for the supply of electricity and therefore subject to the RITC requirement
Consideration, Price Adjustment, or Tax We will now consider whether the GA is consideration for the supply of electricity, a price adjustment for the supply of electricity, or a tax, fee, or duty. Is the GA Consideration? The issue is whether the GA is part of the consideration for the supply of energy (which includes ancillary services) or whether it represents a separate supply. Section 123 defines consideration to include any amount that is payable for a supply by operation of law. ...
GST/HST Interpretation
31 July 2003 GST/HST Interpretation 45570 - AND APPLICATION RULING [Consideration for Leased Facilities Where the Tenant is a Public Service Body Organizing a Games Event]
The "value of the consideration" is defined under subsection 153(1) as "(a) where the consideration or that part (of the consideration) 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. ... The "value of the consideration" is defined under subsection 153(1) as "(a) where the consideration or that part (of the consideration) 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. ... Host Org B pays no other consideration to Owner A for the use of the venue. ...
GST/HST Interpretation
14 June 1999 GST/HST Interpretation HQR0001750 - Consideration
Answer For GST purposes, a rebate paid to a XXXXX under the XXXXX does not reduce the value of the consideration for the supply. ... Section 123 of the ETA provides that "consideration" includes any amount that is payable for a supply by operation of law. ... The value of the consideration for the XXXXX purchased by XXXXX includes the market price, the XXXXX[.] ...