GST/HST Severed Letters - 2024-09

HST severed letters, 2024-09

GST/HST Interpretation

27 September 2024 GST/HST Interpretation 242630 - Trans-border air charters to the United States of America with a stop of 24 hours or less

CRA Tags
ETA Sch VI, Part VII Sec. 1(1), Part VII Sec. 2, Part VII Sec. 3, ETA Sch IX, Part VI Sec. 1, SOR/2010-117 New Harmonized Value-added Tax System Regulations: 13, 20, 21

3 September 2024 GST/HST Interpretation 247914 - Eligibility for the purpose-built rental housing rebate and duplexes

CRA Tags
ETA Part IX, 123(1) “multiple unit residential complex”, “condominium complex”, “residential condominium unit”, “residential complex”, “residential unit”, 256.2, Real Property (GST/HST) Regulations
Summary Under
Tax Topics - Excise Tax Act - Regulations - Real Property (GST/HST) Regulations - Section 4 - Subsection 4(2) - Paragraph 4(2)(a)
two rental duplexes with shared wall on one legal title constituted a single building, so that they could qualify

14 August 2024 GST/HST Interpretation 247708 - […][the Company] and the purpose-built rental housing (PBRH) rebate

CRA Tags
ETA Part IX, 123(1) “multiple unit residential complex”, “residential complex”, “residential unit”, 191, 256.2, Real Property (GST/HST) Regulations
Summary Under
Tax Topics - Excise Tax Act - Regulations - Real Property (GST/HST) Regulations - Section 4 - Subsection 4(2) - Paragraph 4(2)(a)
two separate rental duplexes on one legal title would not qualify for the PBRH rebate/ question of fact whether connecting hallway made them one building instead
Words and Phrases
building
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Residential Complex
separate buildings on the same land are separate residential complexes

13 August 2024 GST/HST Interpretation 247663 - Strata-titled townhomes and the purpose-built rental housing (PBRH) rebate

CRA Tags
ETA Part IX, 123(1),191,256.2, Real Property (GST/HST) Regulations
Summary Under
Tax Topics - Excise Tax Act - Regulations - Real Property (GST/HST) Regulations - Section 4 - Subsection 4(2)
a municipal bylaw requiring division of an apartment building into condo rental units could preclude access to the purpose-built rental housing (PBRH) rebate
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Multiple Unit Residential Complex
rental apartment building would not qualify as a MURC if it was required to be strata-titled

30 May 2024 GST/HST Interpretation 246958 - Zero-rated Supplies of Financial Services and Eligibility for Input Tax Credits

CRA Tags
ETA Part IX, 123(1)("financial instrument"), 123(1)("financial service"), 123(1)("supply"), 141.01, 141.02, ETA Schedule VI, Part IX Sec. 1
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1
a financial institution’s investment in a non-resident partnership generally does not give rise to zero-rated supplies after the initial investment
Summary Under
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(1) - Non-Attributable Input
annual financial statement preparation was non-attributable input
Summary Under
Tax Topics - Income Tax Act - Section 96
non-resident partnership with no interest in the partnership of the GP and no liability of the partners for partnership debts might not be a partnership
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f)
partnership distributions are not for a supply, or come within (f)
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (n)
money contribution to a mooted partnership was excluded under (n) if the purported partnership interest received therefor did not qualify as such and was not a financial instrument

GST/HST Ruling

12 September 2024 GST/HST Ruling 229977 - Supply of canary seeds

CRA Tags
ETA Sch VI, Part IV Sec. 2

12 September 2024 GST/HST Ruling 246662 - Application of GST/HST on the supply of […][bites]

CRA Tags
ETA Sch VI, Part III, 1(e)

11 September 2024 GST/HST Ruling 247361 - GST/HST Status of […][a chocolate product]

CRA Tags
ETA Sch VI, Part III, 1(e)

9 September 2024 GST/HST Ruling 247572 - Eligibility for the purpose-built rental housing rebate

CRA Tags
ETA Part IX, 123(1) – condominium complex, multiple unit residential complex, property, real property, residential complex, residential unit; 221(2), 228(4), 256.2, Real Property (GST/HST) Regulations

3 September 2024 GST/HST Ruling 247578 - GST/HST Status of […][bites]

CRA Tags
ETA Sch VI, Part III, 1(l)

3 September 2024 GST/HST Ruling 247720 - Application of GST/HST on the supply of […][bites]

CRA Tags
ETA Sch VI, Part III Sec 1

21 July 2023 GST/HST Ruling 200294 - Drop shipment of […][machinery parts]

CRA Tags
ETA Part IX, 179(2), 261

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