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28 February 2019 CBA Roundtable

Rather, the $1.00 fee would apply, making the transaction exempt by virtue of the nominal consideration rule. ... CRA’s response was essentially that this would be taken “under consideration” regarding certain cases. ... Further, a determination of whether novation occurs in a particular case requires consideration of all relevant facts. ...

24 February 2000 CBA Roundtable

We confirm that the fees charged would be consideration for a taxable supply. ... In consideration for its efforts, YCo is compensated by management fees calculated on an annual basis. ... This deemed consideration occurs whether or not the partner charges a fee to the partnership. ...

Subsection 2(1) - Related Provisions

Every person who tenders for registration a conveyance by which any land is conveyed to or in trust for a transferee shall pay to the Chief Financial Officer, when the conveyance is tendered for registration or before it is tendered for registration: A. a tax computed at the rate of: (1) one-half of 1 percent of the value of the consideration for the conveyance up to and including $55,000; (2) 1 percent of the value of the consideration which exceeds $55,000 up to and including $400,000; (3) 1.5 percent of the value of the consideration which exceeds $400,000 up to and including $40 million; (4) 1 percent of the value of the consideration which exceeds $40 million; B. if the value of the consideration for the conveyance exceeds $400,000 and the conveyance is a conveyance of land that contains at least one and not more than two single family residences, an additional tax of: (1) one-half of 1 percent of the amount by which the value of the consideration exceeds $400,000 up to and including $40 million; and (2) 1 percent of the amount by which the value of the consideration exceeds$40 million. ...

10 October 2014 TTPG Seminar

Respecting the tests in s. 20(1)(c)(ii), it might be considered that the note was consideration for property acquired. ... Section 80 of the ITA and reverse earn-outs Q.4(a) No s. 143.4 grandfathering In a situation involving the purchase of shares of a target corporation ("Target") by a newly formed corporation ("Newco") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven), can the CRA confirm that a reduction in the cost of the shares of Target (through the application of subsection 143.4(2) of the ITA) prior to the subsequent merger of Target with Newco would allow the debt to qualify as an "excluded obligation" (as defined in subsection 80(1) of the ITA) and, consequently, the settlement of the debt following the merger should not result in a "forgiven amount" (as defined in subsection 80(1) of the ITA)? ... In particular, the amendment of Reg. 5907(6) effective 18 December 2009 to no longer preclude the use of Canadian currency, did not affect the general considerations discussed by him. ...

2 December 2014 Annual CTF Roundtable

If there is a standard contractual recital of $1 (but not a dollar more) of consideration and other good and valuable consideration, as an administrative concession CRA will consider that this does not preclude the exceptions from exemption from s. 68 allocation treatment from being available. ... The CRA is now prepared to accept that where a contract relating to granting a restrictive covenant uses words such as “$1 and other good and valuable consideration” simply to ensure that the contract is legally binding, and means in effect that “no more than a $1 worth of consideration” is conveyed by a purchaser for the restrictive covenant, such consideration will not, in and of itself, constitute proceeds received or receivable by the particular party for granting the RC for purposes of paragraph 56.4(6)(e) and paragraph 56.4(7)(d). ... If more than nominal consideration of $1 is paid for a restrictive covenant under the wording “$1 and other good and valuable consideration”, the exceptions set out in subsections 56.4(6) and (7) would not apply because the respective conditions in paragraph 56.4(6)(e) and paragraph 56.4(7)(d) would not be met. ...

24 February 2011 CBA Roundtable

B Co makes a damage payment to A Co in respected of the destroyed railcar otherwise than as consideration for the lease of the railcar. ... Under subsection 168(6) where tax is payable on a day for the supply of tangible personal property or real property and the value of the consideration or a part of the consideration for the supply of tangible personal property or real property is not ascertainable on that day, the tax becomes payable on the day the value of that consideration becomes ascertainable. ... If so, how would the value of the consideration for the supply be determined for purposes of applying the GST? ...

9 March 2006 CBA Roundtable

The payment is an amount other than consideration for the supply under the agreement. ... Furthermore, subsection 152(2) provides that consideration under a lease is deemed to become due when Tenant B is required to pay “the consideration” – does this refer back to subsection 168(9)? ... Pursuant to subsection 168(9) of the Act, a “deposit” given in respect of a supply would not become consideration paid for the supply until Landlord A applies it as consideration for the supply. ...

3 March 2005 CBA Roundtable

Subsection 6(3) - Commentary

S. 6(3)(c) refers to an amount received as consideration (or partial consideration) for accepting the office or entering into the contract of employment. ... S. 6(3)(e) refers to an amount received in consideration (or partial consideration) for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment. ... Where on the sale of shares of a company by the owner-manager, monthly payments thereafter received by the individual from his form employer will not be taxable under s. 6(3)(d) or (e) if the payments in substance are not consideration for services or restrictive covenants provided by the former employee (Wilson), even perhaps if the parties purported to agree that the payments would be consideration for consulting services that they had no intention of requesting or providing, as the case may be (Beaupré Estate). ...

28 February 2002 CBA Roundtable

Assume further that the consideration for the transfer of the mortgages/receivables, if supplied separately by Company A, would be greater than 50% of the total consideration for all services or property supplied to the SPV by Company A if that service or property had been supplied separately. ... Where the consideration for the supply is expressed in money, the value of consideration is generally deemed to be the amount of the money under paragraph 153(1)(a) of the ETA. ... Where consideration for the supply is payable under an agreement for the supply, the recipient of the supply is the person who is liable under the agreement to pay that consideration. ...

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