GST/HST Severed Letters

GST/HST Interpretation

13 August 2024 GST/HST Interpretation 246538 - Determining if a limited partner of a partnership can claim an ITC

CRA Tags
ETA Part IX, 272.1(2)
Summary Under
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(2) - Paragraph 272.1(2)(b)
a limited partner can almost never claim an ITC in respect of expenses incurred by it in relation to the partnership business

2 May 2024 GST/HST Interpretation 246050 - Assignment of an interest in real property and direction of title change

CRA Tags
ETA Part IX, 155, 192.1, 256.2
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply
a direction letter to change how title is conveyed at closing gives rise to a real estate supply
Summary Under
Tax Topics - Excise Tax Act - Section 155
s. 155 engaged where two related individuals with respective new condo purchase agreements directed that title to both be transferred to them in co-tenancy
Summary Under
Tax Topics - Excise Tax Act - Section 192.1
s. 192.1 engaged where two related individuals with respective new condo purchase agreements agreed to assign interests in their purchase agreements so as to acquire in co-tenancy
Summary Under
Tax Topics - Excise Tax Act - Section 256.2 - Subsection 256.2(3)
where condo unit acquired in co-ownership, NRRP rebate conditions applied separately to each purchaser

GST/HST Ruling

21 August 2024 GST/HST Ruling 174773 - Tax status of the installation of artificial teeth by a dental practice

CRA Tags
ETA Part IX, Sch V, Part II Sec. 5, Sch VI, Part II Sec. 11

1 August 2024 GST/HST Ruling 245954r - […][prepackaged, ready-to-drink beverage]

CRA Tags
ETA Part IX, 165(3), ETA Sch VI, Part III Sec. 1(n)

Underused Housing Tax (HST) Interpretation

4 June 2024 Underused Housing Tax (HST) Interpretation 246062 - Application of the UHT to bare trusts

CRA Tags
UHTA Part 1 - Interpretation and General Rules of Application (2-4): 2, UHTA Part 4 - Returns (7-10): 7(1)

4 June 2024 Underused Housing Tax (HST) Interpretation 246071 - Definition of “excluded owner”

CRA Tags
UHTA Part 1 - Interpretation and General Rules of Application (2-4): 2, UHTA Part 4 - Returns (7-10): 7(1)

Underused Housing Tax (HST) Ruling

4 June 2024 Underused Housing Tax (HST) Ruling 246047 - AND UHT INTERPRETATION GST/HST - Obligation to file UHT returns

CRA Tags
UHTA Part 1 - Interpretation and General Rules of Application (2-4): 2, UHTA Part 4 - Returns (7-10): 7(1):

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