GST/HST Severed Letters - 2021-08

HST severed letters, 2021-08

GST/HST Interpretation

17 August 2021 GST/HST Interpretation 207227 - Tax status of supplies made to a payment processor

CRA Tags
ETA Part IX, 123(1), ETA Sch V, Part VII Sec. 1
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)
payment processor marketer with some discretion generated arranging-for fees

27 July 2021 GST/HST Interpretation 197267a - Allocation to a general partner

CRA Tags
ETA Part IX, 123(1), 272.1, ETA Sch V Part VII Sec. 1
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership
ILP status can be derived from investing in other partnerships
Summary Under
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(1)
draws to GP disproportionate to partnership capital is indicative of the receipt by it of such draws as consideration for services
Summary Under
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(3) - Paragraph 272.1(3)(b)
a manager cannot earn its fee directly from the ILP, and the deemed FMV supply by the GP is based on industry norms

6 July 2021 GST/HST Interpretation 206211 - Assignment of an agreement of purchase and sale of a condominium unit

CRA Tags
ETA Part IX: 123(1); Sch V, Part 1 Sec. 2

GST/HST Ruling

3 August 2021 GST/HST Ruling 211272 - Assignment of a right to purchase a residential condominium unit

CRA Tags
ETA Part IX, 123(1), ETA Sch V, Part 1 Sec. 2

3 August 2021 GST/HST Ruling 216320 - Transfer of ownership of a Trailer

CRA Tags
ETA 123(1), 165

27 July 2021 GST/HST Ruling 223588 - […][Whether zero-rated - Supply of [X], a cell phone]

CRA Tags
ETA Sch VI, Part II Sec. 7

13 July 2021 GST/HST Ruling 212992 - Question on eligibility for 83% Public Service Bodies Rebate

CRA Tags
ETA Part IX, 259
Summary Under
Tax Topics - Excise Tax Act - Section 259 - Subsection 259(2.1) - Paragraph 259(2.1)(a)
a palliative care facility could only qualify for the (enhanced) PSB rebate once it commenced operations

13 July 2021 GST/HST Ruling 215808 - – […][Supplies of services of tutoring or instructing]

CRA Tags
ETA Sch V, Part III, Sec. 9(a)

6 July 2021 GST/HST Ruling 213839 - – Sale of vacant land

CRA Tags
ETA Schedule V Part 1, section 9

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