GST/HST Severed Letters - 2019-05

HST severed letters, 2019-05

Excise Ruling

GST/HST Interpretation

18 March 2019 GST/HST Interpretation 186839 - Personnes morales étroitement liées

CRA Tags
ETA Part IX, 128(1), 128(1.1), 128(4)
USA of shareholders of parent corporation stripped it of its qualifying voting control of its subsidiaries
a USA stripped away voting control of a parent over its wholly-owned subs

GST/HST Ruling

27 May 2019 GST/HST Ruling 189695r - Supply of prepared meals by a charity.

CRA Tags
ETA Part IX, 148, 148.1, 165, 240(1), ETA Sch V, Part V.1 Sec. 1(d),Part V.1 Sec. 5.1:

14 May 2019 GST/HST Ruling 174476 - Tax status of […][non-carbonated fruit flavoured beverages]

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

10 May 2019 GST/HST Ruling 167225 - Royalty Payments

CRA Tags
ETA Part IX, 123(1)(consideration), 123(1)(debt security), 123(1)(financial instrument), 123(1)(financial service), 123(1)(supply), 123(1)(taxable supply), ETA Sch V, Part VII Sec. 1
a loan assimilated to a royalty agreement, so that "principal" advanced was taxable
loan and royalty advance were consideration for single taxable supply of IPP

2 May 2019 GST/HST Ruling 150998 - Fees charged in relation to project loans

CRA Tags
ETA Part IX, 123(1), 138, 139, 165, ETA Sch V, Part VII, SOR/91-26 Financial Services (GST) Regulations
non-refundable fee paid by borrower to lender’s agent to perform due diligence and take the financing project through to closing were taxable preparatory services
predominant nature of fees paid to loan agent was for loan management
fee paid for taking a financing from signing through to closing is taxable