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CRA responded: Under section 238 … every registrant is required to file a GST/HST return for each of their reporting periods in accordance with the timing requirements set out in that section…. ...

CRA also indicated that the “general presumption that a sole employee-shareholder receives a benefit or an allowance in his or her capacity as a shareholder … may not apply if the benefit or allowance is comparable (in nature and amount) to benefits and allowances generally offered to non-shareholder employees of similar-sized businesses, who perform similar services and have similar responsibilities.” ...

. … The addition of a medical escort along with medical equipment and supplies would not transform a commercial aircraft into an air ambulance. ...

V, Pt, II, s. 5, depending on who accompanied the patient – whereas if the attendants were paramedics it would not be exempted. ...

After finding that the repatriation services were a single supply, CRA went on to state: [N]ursing … includes activities such as providing treatment, assessing the health care needs of […][an individual], analyzing the findings of a health assessment, and determining the appropriate service, treatment or equipment. ...

Pizzitelli J applied the single supply doctrine in finding that the predominant element of what was being supplied by the dealer was an exempt supply of arranging for the insurance – and that the exclusion in (r.4) of the definition of an exempt financial services for promotional and various administrative services did not apply. ...

CRA responded: As indicated … Memorandum 16-5 [para. 33] VDP applicants are required to submit information for the four calendar years before the date the application is filed for applications under Category 1 or Category 2. ...

. … [T]the NVCC is currently responding to requests for call-backs promptly. ...

. … [T]here are three essential qualities that help in determining whether a person is acting as agent in making a transaction on behalf of another person. ...

Since s. 256.1 only referenced ss. 6.1 and 6.11, DeveloperCo was not entitled to a rebate under s. 256.1 for the HST charged to it on the development costs borne by it – notwithstanding that the transactions generated fully-taxable revenues from the sublease purchasers. ...