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Underused Housing Tax Notice UHTN13 Exemptions for New Residential Properties February 2023-- summary under Paragraph 6(7)(k) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 6- Subsection 6(7)- Paragraph 6(7)(k) Application of GST/HST guidelines on meaning of “substantial completion” What is substantial completion … The … CRA … has guidelines and criteria under the goods and services tax/harmonized sales tax (GST/HST) to determine when construction is substantially completed. ...

P-208R "Meaning of Permanent Establishment in Subsection 123(1) of the Excise Tax Act (the Act)" 23 March 2005-- summary under Permanent Establishment Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Permanent Establishment Meaning of fixed place of business …The fact that space at the disposal of a particular person is at the place of business of another person does not preclude the possibility that that space may be considered to be a place of business of the particular person … [f]or instance … space at the disposal of a non-resident at its client’s premises that is necessary for the non-resident to perform the service that it has agreed to supply to the client in the ordinary course of its business. … Space at the disposal of a person can also exist at the location of equipment or machinery that is at the disposal of the person. … The place of business must be “fixed” in that it must be established at a particular location with a certain degree of continuity and permanency. … [I]t is not necessary that the equipment be affixed to real property to be considered fixed. Rather, the equipment must merely remain at the place of business for a sufficient period of time to be considered fixed. … There must be control at the place of business. … Control can … exist at a place of business where employees are not required to be present in order for important operational decisions to be made, such as … where operational activities … are carried out through automated equipment at the disposal of the business. … The presence of personnel … is not required … if no personnel are required at that location to operate the equipment …. ... There must be a large degree of involvement through the fixed place of business in making or facilitating supplies by the person. … The presence of any of these factors is usually enough to indicate that supplies are being made through a fixed place of business: there is authority at the fixed place of business to enter into contracts or accept purchase orders for the provision of supplies to other persons and that authority is regularly exercised; the tangible personal property that is being supplied is physically manufactured or produced at the fixed place of business; if the supply is a service, the service is performed at the fixed place of business; or, the service of maintaining equipment supplied by the non-resident person, is performed at the fixed place of business (e.g., an authorized factory repair outlet). … A fixed place of business of a particular person that is used solely for the purpose of carrying on activities that are of a preparatory or auxiliary nature in relation to the particular overall business activity of the person does not constitute a fixed place of business of the person through which the person makes supplies. ...

Example 7 – Service supplied in a participating province In a claim period, a non-registrant PSB acquires software programming services from a supplier in Ontario for $35,000. ... The PSB pays $4,550 in HST ($35,000 × 13%). … The PSB is required to self-assess tax at the rate of 2% on the value of the consideration for the supply of the services purchased in Ontario (2% being the difference between the 10% rate of the provincial part of the HST in Prince Edward Island and the 8% rate of the provincial part of the HST in Ontario) to the extent (expressed as a percentage) that the services are used in Prince Edward Island. The PSB self-assesses tax of $140 ($35,000 × 2% × 20%) on Form GST489…....refer to NOTICE 266.... ...

V, and was subject to GST/HST, CRA stated: … The consideration paid or payable must be directly linked to a supply of a health care service that is in fact rendered by a physician to a particular individual. … … [T]he hospital acquired a right to call upon the physician to attend the hospital during a given time period. ... …For purposes of the GST/HST, “property” is defined in subsection 123(1) to mean any property, … and includes a right or interest of any kind …. As consideration for a supply of “property”, the hospital on-call fee is not consideration paid or payable for a supply of a service for GST/HST purposes. … CRA went on to note: If a physician’s only taxable income is generated from hospital on-call fees and these fees do not exceed the small supplier threshold, the physician would qualify as a small supplier and as such not be required to register and charge GST/HST on this fee. ...

. … … [T]he Service Agreement provides, in part, that any notice or other communication to the Council shall be delivered or sent to:[…][Contact information of the Council]. … Under the rules above, the place of supply of the services supplied under the Service Agreement is [Province X]. To be a “practitioner” for purposes of the exemption in section 7.1 of Part II of Schedule V, paragraph (b) of the definition of “practitioner” provides that you must be registered with the regulatory body or professional college for dietitians practising in the province in which the service is supplied. … ...

. … … Results of the 2013-14 Audit Program Outcome Files Percentage Education letter 513 61.0 Compliance agreement 137 16.5 Clean 112 13.5 Notice of intent to revoke issued 34 4.0 Voluntary revocation 20 2.5 Other (part V audits, pre-registration audits, etc.) 13 1.5 Annulment 6 0.5 Sanctions 5 0.5 Total (excluding political activities audits) 840 100.0 Tax shelter audits (p. 37:6) [T]he CRA…will continually audit tax shelter gifting arrangements, which includes auditing all registered charities that play a role in a tax shelter gifting arrangement. ...

Mail one completed copy of this election (plus attachments), separately from any tax return, to your tax centre by the due date identified in [Reg.] 5902(5) …. ... Surplus calculations must be filed with this election … Late or amended elections Late-filed election – subsection 93(5) – we will accept an election filed within three years after the due date and consider it to have been filed on the due date, provided an estimate of the penalty described in subsection 93(6) is paid at the time of filing the election. Special cases – subsection 93(5.1) – we may accept an election filed after the three-year due date or an amended election. ...

. … … Based on the information provided, we are unable to determine whether [the Association] is a professional or trade association. However, even if [the Association] were a professional or trade association, … neither the [Designation X] certification nor the …[Certification Y] is recognized by any regulatory body. ...

The maximum … claim using … [this] method is $400 (200 working days) per individual. Eligibility … Each individual working from home who meets the eligibility criteria can use the temporary flat rate method …. This means multiple people working from the same home can each make a claim. … You do not have to: calculate the size of your work space keep supporting documents … Your employer does not have to … complete and sign Form T2200S or Form T2200 Days that can be counted … [include] days you worked part-time hours from home This method can only be used for the 2020 tax year. ...

. … The amount of the forgivable loan will equal 50% of the monthly gross rent payable by the impacted small business tenant during the 4-month period. ... Generally, the remaining part of the refund or adjustment (that is, the difference between the amount of the rent reduction and the amount of the forgivable loan) must be borne by the commercial property owner. … No GST/HST collectible by CMHC on forgivable loans GST/HST implications There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … Requirement to follow s. 232 re rent reductions Application of GST/HST to refunds or adjustments of the gross monthly rent paid or payable The rent reduction agreement … has the effect of reducing the amount of consideration payable for a taxable supply of real property made by way of lease, licence or similar arrangement …. … [P]ursuant to a rent reduction agreement, a commercial property owner agrees to subsequently reduce an impacted small business tenant’s monthly gross rent payable by at least 75% for the 4-month period. Pursuant to section 232 … in this case where a commercial property owner agrees to refund or credit an amount of GST/HST already collected, or agrees to adjust the GST/HST applicable to the reduction of the monthly gross rent payable, the commercial property owner must issue a credit note, meeting the prescribed requirements that are set out in the Act, to the impacted small business tenant. ...