Subsection 153(1) - Value of Consideration
Cases
Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | "consideration" under law of contract | 111 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (g) | commercial efficacy of arrangement involving kiosk and support services turned on the advance of money | 418 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | three elements integrally connected | 230 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) | predominant element not described in (r.4) or (r.5) | 179 |
Canada v. Costco Wholesale Canada Ltd., 2012 FCA 160
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) | Costco agreement to use Amex cards exclusively was "arranging for" support of Amex's supply of credit | 234 |
See Also
ING Intermediate Holdings Ltd v HMRC, [2017] EWCA Civ 2111
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | services provided in deposit-taking business were more than peripheral so that supplies were made | 262 |
| Tax Topics - General Concepts - Substance | court only goes behind the contract if the contract does not reflect the true agreement | 173 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (c) | borrowing is not by itself a supply by borrower | 61 |
GEM Health Care Group Limited v. The Queen, 2017 TCC 13
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| Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) | issuance of credit note is mandatory for ITC claim | 159 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | no barter of managment services between affiliates/construction supplies acquired by parent as agent for owner-subs | 192 |
| Tax Topics - General Concepts - Agency | construction supplies acquired by parent as agent for subsidiary owning the real estate | 360 |
Invesco Canada Ltd. v. The Queen, 2014 TCC 375
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | management fee distributions to large MFT unitholders | 155 |
| Tax Topics - General Concepts - Evidence | evidence of surrounding circumstances including income tax objective relevant to contract interpretation | 152 |
GF Partnership v. The Queen, 2013 TCC 53, aff'd 2013 FCA 260
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Excise Tax Act - Section 154 - Subsection 154(1) | 126 | |
| Tax Topics - Excise Tax Act - Section 254 - Subsection 254(6) | developer ought to have known that development levies not incurred by it as agent | 286 |
| Tax Topics - Excise Tax Act - Section 296 - Subsection 296(2) | 155 |
British Columbia Transit v. The Queen, [2006] GSTC 103, 2006 TCC 437
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(1.1) | lease consideration not nominal because of property tax obligation | 172 |
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(3) | lessor required to demonstrate taxable-supply-for-consideration purpose | 140 |
| Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | additional reasons can be raised in Notice of Appeal | 235 |
Customs and Excise Commissioners v. Tron Theatre Ltd., [1994] BTC 5028 (Ct. Ses. (I.H.))
Trafalgar Tours Ltd. v. Customs and Excise Commissioners, [1990] BTC 5003 (C.A.)
Administrative Policy
Taxable Supplies - Special Cases [CRA website]
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| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(4) | 241 | |
| Tax Topics - Excise Tax Act - Section 175.1 | 159 |
23 December 2013 Internal T.I. 2013-0514701I7 - Bitcoins
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | sale of Bitcoins can be on capital account | 54 |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | sale for Bitcoins | 60 |
31 July 2012 Interpretation Case No. 103548
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| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 | 133 |
29 July 2011 Headquarters Letter 95868
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | loyalty card promotion | 175 |
15 August 2006 Ruling Case No. 56497 [bonus property with more than nominal value]
23 December 2002 Technical Interpretation RITS 38588
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 165 - Subsection 165(1) | 66 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | municipal taxes paid by tenant are additional rent | 66 |
27 February 2001 Interpretation 33200
2 January 1996 Ruling Case No. 11950
RC4082 "GST/HST Information for Charities", p. 17 (under "Donations and Gifts")
GST M 300-7 "Value of Supply" under "Monetary and Non-monetary Consideration"
GST M 300-7 "Value of Supply" under "Nil Consideration"
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | 32 |
Articles
Hynes, "VAT and Leases: Surrenders, Re-Grants and Rent-Free Periods", British Tax Review, 1993, No. 6, p. 479.
Subsection 153(2) - Combined Consideration
Cases
See Also
River Road Co-Op Ltd. v. The Queen, [1995] GSTC 34 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 | 54 |
Administrative Policy
5 May 2009 Ruling 108014
CRA Audit Manual §27.6.4
GST/HST Memorandum 13-4, Rebates for Printed Books, Audio Recordings of Printed Books, and Printed Versions of Religious Scriptures July 2002
CBAO National Commodity Tax, Customs and Trade Section – 2000 GST Questions for Revenue Canada, Q.6
GST Memorandum 300-7 "Value of Supply" under "Non-Arm's Length Supplies"
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 155 | 184 |
Subsection 153(3) - Barters Between Registrants
Administrative Policy
5 February 2013 Ruling Case No. 141852
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - 15.2 | 152 | |
| Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) | 148 |
Subsection 153(4) - Used Tangible Personal Property Trade-Ins
Cases
Dimension J.M.M. Inc. v. Canada, 2005 FCA 168
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 299 - Subsection 299(2) | assessment of partnership before assessment of partner not required | 163 |
| Tax Topics - Excise Tax Act - Section 272 - Subsection 272.1(5) | direct assessment of partner was valid | 198 |
Administrative Policy
Taxable Supplies - Special Cases [CRA website]
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | 190 | |
| Tax Topics - Excise Tax Act - Section 175.1 | 159 |
TIB-084, 29 July 1997 "Treatment of Used Goods".
Articles
Steven K. D'Arcy, "Commercial Practices and the GST", Canadian GST Monitor, No. 107, 26 August 1997, p. 1: Discussion of trade-in allowance issues including treatment of liens.
Subsection 153(6) - Exchange of Natural Gas Liquids for Make-Up Gas
Administrative Policy
GST/HST Memorandum 4.5.2 "Exports – Tangible Personal Property" August 2014
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