Section 153

Subsection 153(1) - Value of Consideration

Cases

Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269

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Words and Phrases
consideration
Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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
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.))

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Trafalgar Tours Ltd. v. Customs and Excise Commissioners, [1990] BTC 5003 (C.A.)

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Boots Co. plc v. Customs and Excise Commissioners, [1990] BTC 5064 (Ct. J.E.C.)

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Administrative Policy

Taxable Supplies - Special Cases [CRA website]

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23 December 2013 Internal T.I. 2013-0514701I7 - Bitcoins

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31 July 2012 Interpretation Case No. 103548

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29 July 2011 Headquarters Letter 95868

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Locations of other summaries Wordcount
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]

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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

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2 January 1996 Ruling Case No. 11950

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RC4082 "GST/HST Information for Charities", p. 17 (under "Donations and Gifts")

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GST M 300-7 "Value of Supply" under "Monetary and Non-monetary Consideration"

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GST M 300-7 "Value of Supply" under "Nil Consideration"

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Locations of other summaries Wordcount
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

Ladas v. Canada, 2002 FCA 237

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See Also

River Road Co-Op Ltd. v. The Queen, [1995] GSTC 34 (TCC)

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Administrative Policy

5 May 2009 Ruling 108014

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CRA Audit Manual §27.6.4

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GST/HST Memorandum 13-4, Rebates for Printed Books, Audio Recordings of Printed Books, and Printed Versions of Religious Scriptures July 2002

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CBAO National Commodity Tax, Customs and Trade Section – 2000 GST Questions for Revenue Canada, Q.6

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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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94 CPTJ - Q. 1

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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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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