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 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...

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

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

19 March 2019 GST/HST Ruling 194819 - Para-municipal supplies

CRA Tags
ETA Sch V, Part VI Sec. 28

12 April 2019 GST/HST Ruling 190982 - Supply of various feeding utensils and other gripping devices

CRA Tags
ETA Sch VI, Part II Sec. 38

23 April 2019 GST/HST Ruling 186334 - S AND INTERPRETATIONS - Annual licensing fees and public service bodies’ rebate eligibility

CRA Tags
ETA Part IX, 123(1),259(1), ETA Sch V, Part VI Sec. 18, Part VI Sec. 20(c)
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20
law society was an “other body established by a government”
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 - Paragraph 20(c)
consideration for licensing included expired licence fees
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 - Paragraph 20(b) - Subparagraph 20(b)(i)
exempt processing and registration fees of professional society
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Debt Security
NSF cheque charge exempt as for debt security
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 6
jurisprudence exam fee exempt, but not charge for processing exam administered by another body

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