Section 273

Subsection 273(1) - Joint Venture Election

See Also

Medallion Corporation v. The Queen, 2018 TCC 157

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Words and Phrases
joint venture
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply property manager's share of rents in rental JV was not taxable consideration 329

Lau v. The Queen, [2007] GSTC 171, 2007 TCC 718

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DeWinter v. Consolidated Food Brands Inc. (1998), 43 B.L.R. (2d) 106 (B.C.S.C.)

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Words and Phrases
joint venture

Westcan Malting Ltd. v. The Queen, [1998] G.S.T.C. 34

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Words and Phrases
joint venture

Administrative Policy

May 2017 CPA Alberta Roundtable, GST/HST Q.3

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8 March 2018 CBA Commodity Tax Roundtable, Q.11

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Excise and GST/HST News No. 103, December 2017

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Words and Phrases
joint venture

14 October 2016 Interpretation 170549

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) nominee accepted as registrant 156
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) agent could not claim ITCs 157
Tax Topics - General Concepts - Agency co-owners required to report pro rata portions of sale made by their agent 195

May 2016 Alberta CPA Roundtable, GST Q.3

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26 February 2015 CBA Roundtable, Q. 13

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Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 33(2) 2 related agreements qualify as “an agreement” 129

26 February 2015 CBA Roundtable, Q. 12

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2 December 2014 Interpretation 164212

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17 July 2014 Interpretation 152176

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12 July 2013 Interpretation Case No. 152393

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GST/HST Notice 284 "Bare Trusts, Nominee Corporations and Joint Ventures" February 2014

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1.1) agent not entitled to ITCs 113
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) taxable supply of nominee services 63
Tax Topics - General Concepts - Agency acquisitions of agent those of principal 116

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 30.

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28 March 2013 Interpretation Case No. 151697

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21 January 2013 Interpretation Case No. 146302

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26 November 2012 Interpretation Case No. 148931

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10 May 2011 Headquarters Letter Case No. 103495

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19 December 2008 Ruling Case No. 106868 [purchases of JV interest not covered/mutual control requirement]

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8 March 2007 Canadian Bar Association Commodity Tax Section Roundtable, Q. 30

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26 May 2006 Ruling Case No. 51850 [operator enters into contracts or is responsible for payments]

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9 March 2006 Canadian Bar Association Commodity Tax Section Roundtable, Q. 23

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) 0

Q.23 – Bare Trustee as "Operator" of Joint Venture

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) 25

16 July 2003 Interpretation Case No. 43760

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27 February 2003 Canadian Bar Association Commodity Tax Section Roundtable, Q. 13

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11 February 1994 Interpretation 11660-1/0703

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 167 - Subsection 167(1) transfer of co-ownership interest in commercial real estate JV 147

P-171R "Distinguishing Between a Joint Venture and a Partnership for the Purposes of Section 273 Joint Venture Election" 24 February 1999

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P-138R "The Effect of Making a Joint Venture Election on a Participant's Ability to Register and Claim Input Tax Credits"

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P-106 "Administrative Definition of A 'Participant' in a Joint Venture"

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Articles

Ian V. MacInnes, "GST/HST Joint Venture Election", CCH Canadian Real Estate Income Tax Guide, No. 90, April 2012, p. 1

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Dennis Wyslobicky, "GST and Real Property", 2004 Commodity Tax Symposium, under "5. Real Property Joint Venture - Start-ups".

Forms

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Subsection 273(4)

Administrative Policy

26 February 2015 CBA Roundtable, Q. 15

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 156 - Subsection 156(4) backdated elections 51

P-187 "Prescribed Form for Joint Venture Elections," 16 October 1997

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Subsection 273(5) - Joint and Several Liability

Forms

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