Section 171

Subsection 171(1) - Person Becoming Registrant

Cases

Castle Building Group Ltd. v. Canada (National Revenue), 2021 FC 947

A parent corporation (“Castle”) made some of its taxable supplies of building materials to its wholly-owned subsidiary (“CBS”), which...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 156 - Subsection 156(4) - Paragraph 156(4)(b) - Subparagraph 156(4)(b)(ii) it was not unreasonable of CRA to refuse a late ETA s. 156 election based on a corporation’s failing to file nil returns 558

0741508 B.C. Ltd. and 0768723 B.C. Ltd. (Re), 2014 BCSC 1791

In 2011, the petitioners conveyed undeveloped B.C. lands to a limited partnership. In 2013, CRA assessed the petitioners for their failure to...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Rectification & Rescission failure to file timely tax returns did not invoke the dirty hands bar to equitable rescission 363

Administrative Policy

26 February 2015 CBA Roundtable, Q. 16

Company B transfers its co-ownership interest in a commercial rental property on a rollover basis to Company C, whose sole activity is to hold the...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) backdated registration of unregistered purchaser of commercial real estate 542

15 November 2011 Headquarters Letter Case No. 135608

Where a "capital pool company" which has raised capital pursuant to a prospectus on a blind pool basis has identified an acquisition of assets...

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1996 Corporate Management Tax Conference Round Table, Q. 11

Where a person does not register prior to acquiring a business, it will be subject to s. 171 upon becoming a registrant.

Subsection 171(3)

See Also

Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure)

The appellant, which had been operating a Boston Pizza restaurant on leased premises since 2008, was ordered by the new owner of the land to...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) winding-down operations qualified a de-registrant as a “registrant”/registration retroactive 212
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Registrant registrant based on wind-up activities 62
Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a) holding discontinued equipment 151

Subsection 171(3)

Administrative Policy

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017

Application to public service body

58. Where, at any time in a claim period, a PSB ceases to be a GST/HST registrant, the PSB is deemed under...

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Paragraph 171(4)(b)

Administrative Policy

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017

57. ...

Example 11 – Adjustment to net tax for rental property on becoming a small supplier division

In July, a registrant PSB resident in...

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