14 May 2019 GST/HST Ruling 188253 - Application of GST/HST to […][a Powdered Mix]

CRA Tags
ETA Sch VI, Part III Sec. 1

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

CRA Tags
ETA Part IX, 128(1), 128(1.1), 128(4)
Summary Under
Tax Topics - Excise Tax Act - Section 128 - Subsection 128(4)
USA of shareholders of parent corporation stripped it of its qualifying voting control of its subsidiaries
Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i)
a USA stripped away voting control of a parent over its wholly-owned subs

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
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Debt Security
a loan assimilated to a royalty agreement, so that "principal" advanced was taxable
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply
loan and royalty advance were consideration for single taxable supply of IPP

14 May 2019 GST/HST Interpretation 160444 - Membership fee

CRA Tags
ETA Part IX, 123(1)

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
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4)
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
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3)
predominant nature of fees paid to loan agent was for loan management
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)
fee paid for taking a financing from signing through to closing is taxable

9 August 2017 Excise Ruling 181882 - – [Sale of Diesel Fuel]

CRA Tags
ETA Part VII, 66

Cortland/Pure Multi-Family -- summary under LP Acquisitions

Thursday, September 5, 2019 - 00:15 | Author: sfarmstrong

It is proposed that an LLC (the “Purchaser”) that is an affiliate of a third party (Cortland) acquire for cash all the (listed) Class A units and (unlisted but convertible) Class B units of Pure Multi-Family REIT LP (“Pure Multi-Family”). The US rental portfolio of Pure Multi-Family is held through a US private REIT.

Cortland/Pure Multi-Family -- summary under Corporation Acquisitions of LPs

Wednesday, September 4, 2019 - 23:33 | Author: narmstrong

Overview

It is proposed that an LLC (the “Purchaser”) that is an affiliate of a third party (Cortland) acquire for cash all the (listed) Class A units and (unlisted but convertible) Class B units of Pure Multi-Family REIT LP (“Pure Multi-Family”). The US rental portfolio of Pure Multi-Family is held through a US private REIT.

4 January 2019 Excise Interpretation 195632 - Cigars Imported into Canada and […][Country X]

CRA Tags
Excise Act, 2001, sections 32, 38, and 51

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