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GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Clause 6(2)(b)(i)(A) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(2)- Paragraph 6(2)(b)- Subparagraph 6(2)(b)(i)- Clause 6(2)(b)(i)(A) Reasonableness of regarding an address as a business address 39. ... [This rule] does not require a supplier to obtain an address of the recipient that the supplier does not already obtain in the ordinary course of its business. … 42. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.7-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) generally no ETA s. 285 gross negligence penalty for interpretive errors ...

John Lorito and Trevor O'Brien, "International Finance – Cash Pooling Arrangements," draft version of paper for CTF 2014 Conference Report.-- summary under Paragraph 90(7)(a) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(7)- Paragraph 90(7)(a) In the case of notional pooling, loans to and from the third party bank may be subject to the upstream loan rules through the application of the back-to-back loan rule in subsection 90(7)…. ...

"Splane & Reimburs of Increased Loan Costs on Relocation")-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Comments on method of calculation of benefits where an employer pays relocation reimbursements to transferred employees in respect of increased housing costs in the new location. ...

TPM-05R – Requests for Contemporaneous Documentation 28 March 2014-- summary under Section 26 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 26 19. ...

P113 – "Gifts and Income Tax" 2013-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other Fair market value (FMV)—This is usually the highest dollar value you can get for your property in an open and unrestricted market, between a willing buyer and a willing seller who are acting independently of each other. ...

P113 – "Gifts and Income Tax" 2013-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts Fair market value (FMV)—This is usually the highest dollar value you can get for your property in an open and unrestricted market, between a willing buyer and a willing seller who are acting independently of each other. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23 ("Pre-incorporation Contract")-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) In response to a question on pre-incorporation contracts, CRA stated: To the extent that the adoption of a pre-incorporation contract is in connection with acquiring or establishing the commercial activities of a newly formed corporation, paragraph 141.1(3)(a) of the ETA will deem the adoption of that contract to be done in the course of the corporation's commercial activities. ...

IT-114 — Discounts, premiums and bonuses on debt obligations-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Cancelled 29. ...

CBA National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 21. ...