Section 186

Subsection 186(1) - Related Corporations

See Also

Miedzi Copper Corporation v. The Queen, 2015 TCC 26 (Informal Procedure)

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Words and Phrases
in relation to

Pay Linx Financial Corporation v. The Queen, 2011 TCC 203 (Informal Procedure)

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Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) "acquisition" of shares includes cancellation of those shares on a Delaware merger; "in relation to" to be construed broadly 305

Perfection Dairy Group Limited v. The Queen, 2008 TCC 342 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) fees were incurred in relation to claim of bankrupt subsidiary rather than to earn consulting fees 152

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable, Q.14

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23 November 2016 Interpretation 165129

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) expenses incurred respecting a subsidiary unit trust are ineligible for ITCs unless incurred as management-services inputs 161

GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017

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May 2016 Alberta CPA Roundtable, GST Q.14

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26 February 2015 CBA Roundtable, Q.21

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 156 - Subsection 156(1) - Qualifying Member s. 186(1) does not deem use of property in commercial activity 58

26 February 2015 CBA Roundtable, Q. 17

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 34

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 217 - Imported Taxable Supply failure to self-assess under s. 218 where satisfy s. 186(1) 61
Tax Topics - Excise Tax Act - Section 281.1 - Subsection 281.1(1) failure to self-assess under s. 218 where satisfy s. 186(1) 61

27 March 2009 Interpretation 106684

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P-196R "Whether Administrative Overhead Costs Fall Under Subsection 186(1) of the Excise Tax Act", August 10, 2007.

29 November 2004 Interpretation 54669

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(4) Holdco eligible for ITCs on inputs used by it to make free supplies to Opco 214

GST M 700-5-6 "Input Tax Credits for Holding Companies, Takeovers, and Multi-Tiered Corporations"

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) 0

Guide for Providers of Financial Services under "Special Provisions" - "Investments by Related Corporations"

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Articles

Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax, Federated Press, Volume XIII, No. 2, 2015, p. 674.

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Subsection 186(2) - Takeover Fees

See Also

Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285

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Words and Phrases
in relation to acquisition
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) listing fees to issue shares to target shareholders were eligible 255

Administrative Policy

15 November 2011 Headquarters Letter Case No. 135608

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GST M 700-5-6 "Input Tax Credits for Holding Companies, Takeovers, and Multi-Tiered Corporations"

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) 0