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CRA ruled that USco, following the New Services addition, is not carrying on business in Canada for GST/HST purposes – and also ruled that the supply of the New Services by Canco to USco is zero-rated pursuant to Sched. ...

However, it is necessary to read this rule in a purposive manner in order to make it work given that the operation of s. 104(13) dovetails with the s. 104(6) rule, which references an amount of income “that the trust claims” – whereas “it could be expected that such a trust will not file a Canadian tax return and will not be expressly claiming any deductions under the Act.” ...

Essentially, the SAM formula computes a normative amount of provincial HST based on the residence of the SLFI's ultimate stakeholders, and compares this with the actual provincial HST paid to its suppliers – and then requires that the difference be reported and claimed as refunds or remitted as tax, in interim and final returns. ...

– and, as a participant, it could then be designated as the JV operator. ...

CRA accepted the proposition that where a charity would not qualify as being engaged in making taxable supplies until it made a s. 211 election, it nonetheless potentially could register for GST/HST purposes in advance of the effective date of the s. 211 election on the basis of the s. 141.1(3)(a) rule, which effectively assimilates start-up activities to commercial activity – provided that the charity was in a position “to demonstrate a clear intention to engage in a commercial activity.” ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-02-06 5 October 2012 Roundtable, 2012-0453191C6 F- Investissements frauduleux Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) Earl Jones case was “exceptional”: prior years’ returns generally cannot be amended to exclude fictitious income 5 October 2012 Roundtable, 2012-0453911C6 F- Roulement à fiducie pour soi et faculté d'élire Income Tax Act- Section 73- Subsection 73(1.02)- Paragaph 73(1.02)(b)- Subparagaph 73(1.02)(b) trust deed provision that the settlor by will may designate beneficiaries upon death breaches s. 73(1.02)(b)(ii) 5 October 2012 Roundtable, 2012-0454201C6 F- Nouvelle Circulaire- Prix transfert international Income Tax Act- Section 247- New- Subsection 247(2) 2010 OECD Guidelines to be reflected in revised Transfer Pricing Memorandum – not revised IC 87R2 5 October 2012 Roundtable, 2012-0454221C6 F- Allocation des risques et contrôle Income Tax Act- Section 247- New- Subsection 247(2) comment declined re whether Cdn parent bore most of US sub’s risk re operating losses 5 October 2012 Roundtable, 2012-0454051C6 F- Déductibilité de cotisations- caisse de sécurité Income Tax Act- Section 20.01- Subsection 20.01(1) qualifying contribution made to a PHSP by a self-employed professional via a professionals’ union 5 October 2012 APFF Roundtable, 2012-0453211C6 F- Formulaire T1135 Income Tax Act- Section 162- Subsection 162(7) CRA is not bound by Douglas Income Tax Act- Section 220- Subsection 220(3.1) critieria for waiver of penalties and interest ...

Summary of Loblaw Circular under Public Transactions- Spin-offs and Distributions – Butterfly spin-offs. ...

CRA considers that her shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends … notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...

Summaries of Dov Begun “Equity Based Compensation and Stock Options,” 2017 Annual CTF Conference draft paper under s. 5(1), s. 248(1) – salary deferral arrangement, para. ...

Summaries of 27 November 2018 CTF Roundtable, Q.2 under s. 52(2), s. 52(3), s. 53(1)(b)(ii) and s. 89(1) – capital dividend account- (a)(i)(A). ...