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Notice 269 – Draft GST/HST Memorandum 3.7, "Natural Resources" 15 February 2012-- summary under Subsection 162(2) Summary Under Tax Topics- Excise Tax Act- Section 162- Subsection 162(2) Overview of section 162 1. ... The Act does not define "explore" or "exploit" with respect to natural resources. ... The interest usually takes one of two forms – a royalty interest or a working interest. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ("Assumption of ‘Under Water' Contract")-- summary under Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Service A GST-registered Vendor sells resource properties to a GST-registered Purchaser, and Purchaser agrees to assume long-term contracts ("Assumed Contracts") for the processing of the properties' production at prices greater than the current market rates. ... CRA stated: The definition of "service" in [s.] 123(1)… is broad, and… encompasses the assumption of the obligations of another party in return for consideration from the other party. … In this case, the Purchaser has supplied a service to the vendor and GST/HST is collectible on the consideration payable for the supply of the service. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ("Assumption of ‘Under Water' Contract")-- summary under Subsection 152(3) Summary Under Tax Topics- Excise Tax Act- Section 152- Subsection 152(3) A GST-registered Vendor sells resource properties to a GST-registered Purchaser, and Purchaser agrees to assume long-term contracts ("Assumed Contracts") for the processing of the properties' production at prices greater than the current market rates. ... CRA stated: The definition of "service" in [s.] 123(1)… is broad, and… encompasses the assumption of the obligations of another party in return for consideration from the other party. … In this case, the Purchaser has supplied a service to the vendor and GST/HST is collectible on the consideration payable for the supply of the service. ...

. … [R]egistered charities that wanted to work through a non-qualified donee [formerly] could only do this in one way. Charities had to show that the activities were their own, demonstrated by maintaining ongoing direction and control over the use of their resources. 2. … With [the enactment of the qualifying disbursement rules], charities can support the activities of non-qualified donees (grantees), provided charities can show that they meet accountability requirements set out below. … 12. … [A] charity continues to be able to carry on activities using an “intermediary”, provided the charity exercises “direction and control”. … 14. ... A charity may wish to “pool” its resources with multiple organizations (other grantors) when it makes a grant. ...

. … If the company's responsibility is limited to providing registered or licensed nurses to the facility so that the facility may satisfy its own staffing requirements, and the nurses are subject to the control of the operator of the facility and render services under the direction of the facility in accordance with the facility's responsibility to provide care to a patient or resident of the facility, the company has made a taxable supply of personnel or human resources, and not a supply of exempt nursing services. … However, if the company is responsible for the provision of nursing services to the patients or residents of the facility and is accountable for the quality of nursing care provided, the company may have made an exempt supply of a nursing service rendered by a registered or licensed nurse to an individual, where the service is provided within a nurse-patient relationship. ...

. … The direct charge method attaches a specific charge to each identifiable service. The indirect charge method involves an allocation of centralized service costs to particular entities using a basis or allocation key designed to reflect the proportionate benefit received. 11. … As long as the indirect charge results in an allocation that is commensurate with the expected benefit, the OECD accepts such indirect charge methods except in cases where the services are a main business activity of the provider and are also provided to third parties, in which case the direct charge method is preferable. 12. ... [After largely repeating IC 87-2R, paras. 166-170:] Costs of auditing and fundraising for the acquisition of an interest would not be allowed unless the funds were raised on behalf of another member of the group to acquire a new company. 27 28....Sarbanes-Oxley costs…should be reviewed and if the taxpayer can demonstrate that there is a benefit to the taxpayer associated with the charge/expense, it could be allowed as a deduction. … Allocation of corporate group costs 36. … It may be preferable to implement a multiple allocation basis for intra-group services to better reflect the benefits received. … For example, time spent could be an appropriate allocation basis to allocate costs of the tax services, legal services, data processing, and the usage cost of a corporate jet, while the number of employees may be an appropriate basis on which to allocate the costs of the human resources department. … Duplicate costs 38. ...

Summary of line 104 adjustments Line 104 – Adjustments Complete line 104 only if you have to make adjustments to increase the amount of your net tax for the reporting period. ... For more information, see Meal and entertainment expenses. … Summary of line 405 adjustments Line 405 – Other GST/HST to be self-assessed Complete this line if: you are a registrant and have to self-assess the provincial part of the HST on property or services brought into a participating province. ... For more information, see Imported goods and Imported services and intangible personal property. you are an international organization and internal use of a support resource or intangible resource occurs in Canada for a supply of a service or intangible personal property that was made outside Canada, but that is not exclusively (90% or more) for consumption, use, or supply in commercial activities, and you have to self-assess the GST/HST on the deemed supply; or you are a financial institution and a qualifying taxpayer and have to self-assess the GST/HST using the special rules for financial institutions. ...

6 June 2014 Interpretation 150533-- summary under Subsection 162(2) Summary Under Tax Topics- Excise Tax Act- Section 162- Subsection 162(2) distinction between supply of timber harvesting rights and timber harvesting services In finding that an agreement between two forestry companies (Company A and B), under which A Co will manage and harvest timber within B Co's licences, was not for the right to exploit a forestry resource to which s. 162(2) applied, CRA noted that "a person, who cuts trees where the timber remains the property of the person who was originally granted the right to exploit the resource, is not utilizing the resource or turning it to account," and then stated: In substance, the purpose of the agreement is for A Co to supply to B Co a service of cutting trees. This position is supported by the fact that…the agreement states that title to the felled timber passes to B Co when the timber is felled in accordance with the applicable B Co licence. … Since B Co already owns the logs, the amounts paid by B Co are not consideration for a supply of logs by A Co but would appear to be [taxable] compensation paid to A Co for cutting the timber. ...

CRA responded: (a) … [Such] a management or administrative service would typically include managing or administering the day-to-day business and affairs of the partnership. This could include, for example, organizing, monitoring, planning and coordinating the activities of the partnership, making decisions and directing resources to assist the partnership in achieving its defined objectives, as well as maintaining records, and preparing reports. … (b) … The CRA recognizes that there are various methods that may be used and the appropriateness of any valuation methodology used in a particular case is a matter of valuation principles and practice. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. ...

. … Partnerships that carry on business in Canada and Canadian partnerships – A partnership that carries on a business in Canada, or a Canadian partnership with Canadian or foreign operations or investments, must file a return if either of the following occur: at the end of the fiscal period, the partnership has an absolute value of revenues plus an absolute value of expenses of more than $2 million, or has more than $5 million in assets; at any time during the fiscal period: the partnership is a tiered partnership (has another partnership as a partner or is itself a partner in another partnership), or the partnership has a corporation or a trust as a partner, or the partnership invested in flow-through shares of a principal-business corporation that incurred Canadian resource expenses and renounced those expenses to the partnership, or the minister of National Revenue requests one in writing ...