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26 February 2015 CBA Roundtable, Q. 13-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) JV + management agreements can qualify as “an agreement”/“co-ownership agreement” can be a JV agreement Q.1 Can a written agreement, that describes the relationship between the participants as co-ownership of property (rather than as a joint venture), qualify as an agreement evidenced in writing for purposes of s. 273(1)? ... This would require at least two participants being participants under paragraph (a) of the definition of “participant” in… P-106 …. Q.2 In Year 1, Corporations A and B enter into a (joint venture) “Initial Agreement” specifying their rights, responsibilities and relationship and under which they contribute resources and share proportionately in revenue or losses from the joint venture activities. ...

GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Appendix C … General distinction between a regular business and an adventure General approach 3. Generally, a sale made in the course of a business may be distinguished from a sale that constitutes an adventure or concern in the nature of trade by the amount of time, attention and resources devoted to the transaction or by the frequency or regularity of similar transactions. ... Regular sales of property or sales made in a business-like manner as demonstrated by extensive marketing and advertising, or the devotion of extensive time, attention and resources to the sale of the property, would normally be considered as sales made in the course of a business. ...

. … You may also have to report relevant information on Schedule 130 of your partnership information return if you have IFE or IFR, and have a corporation or a trust as a member. If your partnership has a corporation or a trust as a member, under the rules you should complete the following steps: Provide each member with detailed calculations of the partnership’s IFE and IFR Provide each member with detailed calculations of the RAIFE and RAIFR of any CFA of the partnership Notify each member in writing of their allocated share for the year of: IFE in Canadian exploration expenses, Canadian development expenses, Canadian oil and gas expenses, and foreign resource expenses The income or loss that can reasonably be considered to come from activities funded by a borrowing or other financing that results in exempt interest and financing expenses Filing approach before Schedule 130 is ready Schedule 130 … Schedule 130 information is still required even though the form is not available. … Corporations and trusts … When you report your foreign accrual property income, you must adjust for RAIFE denied under subclause 95(2)(f.11)(ii)(D)(I) and include amounts in respect of a CFA’s partnership under subclause 95(2)(f.11)(ii)(D)(II). ... The calculations should include enough details so that a total amount for each paragraph of the relevant definition is shown (refer to subsection 18.2(1)) A calculation of the proportion in subsection 18.2(2) showing an amount for each variable of the formula A calculation of restricted interest and financing expenses for the year, broken down to show amounts restricted under: Paragraph 12(1)(l.2) Subsection 18.2(2), and Subclauses 95(2)(f.11)(ii)(D)(I) and 95(2)(f.11)(ii)(D)(II) If your corporation or trust is a member of a partnership, you must include the share of all relevant partnership amounts when you calculate the corporation or trust’s ATI, IFE, and IFR. … Partnerships When you submit your partnership information return for the fiscal year, you must include the details of how the partnership calculated its IFE and IFR (refer to subsection 18.2(1)). ...

. … Further, the prohibition on both "direct and indirect" partisan political activities is highly subjective (particularly "indirect"), and has been the subject of much confusion in the charitable sector…. ... In other words, charities would not be required to track and report a percentage of resources expended on their political activities (public policy dialogue and development). ... Proposed amendment allowing charities to fully engage in non-partisan public policy dialogue and development that is subordinate to and furthers their charitable purposes (pp. 17-18) Recommendation 3 …The Panel recommends that amendments: retain the current legal requirement that charities must be constituted and operated exclusively for charitable purposes, and that political purposes are not charitable purposes; fully support the engagement of charities in non-partisan public policy dialogue and development in furtherance of charitable purposes, retiring the term "political activities" … and clearly articulating the meaning of "public policy dialogue and development" to include: providing information, research, opinions, advocacy, mobilizing others, representation, providing forums and convening discussions; and retain the prohibition on charities’ engaging in "partisan political activities", with the inclusion of "elected officials" (i.e. charities may not directly support "a political party, elected official or candidate for public office"), and the removal of the prohibition on "indirect" support, given its subjectivity. … The rationale for this approach is more fully described under Recommendation 1 in the context of interim changes recommended to the policy guidance. ...

. … A person shares mining payments when the person shares in the risk of success in the mining activities of the group. … Where a person receives a direct share of the actual mining payment, or a payment or adjustment that is determined based on the actual mining payment earned by the pool or the operator, the person is generally considered to share in the mining payments. ... Another factor to consider in determining whether persons share mining payments within a mining group is whether the operator charges fees to persons with respect to the management or administration of the mining endeavours. … [T]he following types of arrangements for mining would be indicative of a person and a mining pool operator not being members of the same mining group for the purposes of section 188.2: The person is paid by the mining pool operator for the contribution of computing resources by the person and the payment is based on the expected value of the number of blocks validated calculated based on the expected block subsidy regardless of whether the activity gives rise to an actual block subsidy or transaction fee [and similarly where such expected value also includes expected transaction fees]. … Such [person’s] supply is subject to the general GST/HST rules ….. ...