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Administrative Policy summary

10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Subsection 169(1)

However, when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...
Administrative Policy summary

10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Commercial Activity

After ruling that the lump sums so paid are consideration for the taxable supply to Investor of intangible personal property (the right to the royalty payments), CRA went on to find that when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...
Administrative Policy summary

10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Subsection 182(1)

However, when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...

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