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. … Secondary bond purchases generate good interest 35. However, if a person purchases bonds on the secondary market (that is, from a person other than the issuer of the bonds or an agent thereof), the person is not considered to have lent money to the bond issuer. Cash generates bad interest Example 3 … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

. … The courts have found that, in interpreting the meaning of "pertains to" or "incident to" in context, there has to be a financial relationship of dependence of some substance between the property in question and the active business before the property is considered to be incident to or to pertain to the active business carried on by the corporation. ... If a corporation is incorporated to earn income by doing business, there is a general presumption that profits arising from its activities are derived from a business …. ...

. … For example, A and B execute an agreement in which A agrees to sell and B agrees to buy an interest in land. … The consideration is the assumption of an existing mortgage and payment of cash. ...

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 …. ...

. … A written request to have the election or revocation of an election filed late must be submitted to the Assistant Director of Audit of the tax services office of the first specified member making or revoking the election as identified on the Form RC4616. … The written request must provide a clear explanation as to why the specified members have filed the election or revocation late…. ...

After finding that IMEs performed after March 21, 2013 generally are taxable supplies, CRA noted: … In the case where a patient is examined in Canada and the report is prepared outside Canada, the supply of the service is deemed to be made in Canada pursuant to paragraph 142(1)(g), as the services are performed in part in Canada. ... An IME … consists of an examination of the patient, reviewing medical documentation, dictation, editing and printing a report on the findings. ...

. … In each of the examples, a monthly payment based on estimated or actual costs related to a work space in home could be deducted by the corporation, if reasonable in the circumstances. ... If the amount exceeds a reasonable amount, the excess should be reported by the shareholder as a benefit under subsection 15(1). … ...

., roughly on a bi-weekly basis); … registered nurses were at the facility at all times, and nurses were in regular communication with physicians for prescription or advice; the facility received funding for 2.8 hours of care per resident per day …; the care provided was of a different type than ordinary assistance with activities of daily living that a more robust individual might require. ...

. … The fact that the volunteer later donates all or a part of the payment back to the Charity does not impact the Charity's PSB rebate entitlement. ... Therefore, section 175 does not apply and the Charity cannot claim a PSB rebate …. ...

The Lessor, as agent for the Trust, remits the HST paid by the Lessees and pays to the Trust the full amount of the lease payment collected on behalf of the Trust – a portion of which is then paid by the Trust to the Lessor as deferred rent. ... The HST collected on the taxable supply made to the Lessee is accounted for by the Lessor as agent for the Trust (Concurrent Lessee) by virtue of the election under subsection 177(1) between the Trust (Concurrent Lessee) and the Lessor, and […] the MCLA. ...