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. … [T]he word “ownership” generally refers to the legal ownership (that is, “titled” ownership in the case of the underlying real property), rather than equitable ownership of the property. … Based on the assumptions that: (a) the Builder has actual possession of the Developed Lots or the Developed Land pursuant to the Sale Agreement, and (b) the Sale Agreement provides that beneficial ownership of the House or Unit situated on the Developed Lot or Developed Land (as the case may be) is transferred to the Builder at Initial Closing, one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership to the Builder on demand, or to any third party at the Builder’s request (for example, to the Home Buyer …). So, with respect to this scenario, provided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. Therefore … provided that all of the other conditions … are met, the Builder may pay or credit the Rebate to the Home Buyer. ...

Wilson indicated “no” – but noted that the conclusion changes if Company B does not own its own vehicles, but is acting instead as a broker. ... Scenario 6- Landscaping business sells sod Example 4 on CRA’s webpage entitled “ Tax on split income – Excluded shares ” indicated that a cleaning business that spends 15% of its revenue on cleaning products is nevertheless engaged only in cleaning services, because the supply of cleaning products is incidental to the services, whereas Example 6 found that construction materials qualified as a non-service component of a construction business. How would a landscaping business, which generates income from cutting grass, fertilizing, and sodding – which entails buying sod – be treated? ...

Determination of partnership status of foreign partnership by reference to provincial law 20. … Continental Bank … Backman … and Spire Freezers confirmed that the existence of a partnership must be determined by reference to the relevant partnership law of the province or territory and this is the case even when dealing with a partnership established in a jurisdiction outside Canada. ... In addition, express declarations against the existence of a partnership will not be determinative if the facts indicate otherwise. … 31. ... A partnership is distinguished from … other types of relationships and arrangements [which] include joint ventures, co-ownership relationships, and fee-sharing and cost-sharing arrangements. … Whether a partner in a foreign limited partnership need contribute capital 74. … [L]egislation in certain jurisdictions of other countries may permit the formation of a partnership having a legal personality distinct from its members, with limited liability for debts and obligations afforded to all members, including the general partner. ...

Calculate your ITC using the formula: A × (B ÷ C) A is the GST/HST payable by the warranty holder for the goods or services; B is the amount of the reimbursement; and C is the cost to the warranty holder of the repair. ...

. … Therefore … if all the information related to the supply is accessible and is prescribed information that enables the CRA to determine the amount of the ITC, then that information will be acceptable to the CRA as satisfying the documentary requirements under subsection 169(4). ...

B-107 "Investment Plans (Including Segregated Funds of an Insurer) and the HST" April 2013-- summary under Subparagraph 3(e)(i) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 3- Paragraph 3(e)- Subparagraph 3(e)(i) Example of deemed PE where qualified to distribute units through a dealer in a province Permanent establishment in a province – draft SLFI Regulations … Example A mutual fund corporation (MFC) that is a non-stratified investment plan has an office in Ontario, and it is qualified under provincial securities law to distribute units through independent mutual fund dealers in Manitoba. ...

Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021-- summary under Top-Up Percentage Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Top-Up Percentage [Q.20-3] Table of top-up percentages Top-up percentage examples for claim periods 5 to 9 Top-up revenue reduction percentage Top-up percentage Top-up percentage= 1.25 x (top-up revenue reduction percentage – 50%) 70% and over 25% 1.25 x (70%- 50%) = 25% 65% 18.75% 1.25 x (65%- 50%) = 18.75% 60% 12.5% 1.25 x (60%- 50%) = 12.5% 55% 6.25% 1.25 x (55%- 50%) = 6.25% 50% and under 0.0% 1.25 x (50%- 50%) = 0% The overall wage subsidy percentage would be equal to the top-up percentage plus the base percentage. ...

CRA responded: (a) … [Such] a management or administrative service would typically include managing or administering the day-to-day business and affairs of the partnership. This could include, for example, organizing, monitoring, planning and coordinating the activities of the partnership, making decisions and directing resources to assist the partnership in achieving its defined objectives, as well as maintaining records, and preparing reports. … (b) … The CRA recognizes that there are various methods that may be used and the appropriateness of any valuation methodology used in a particular case is a matter of valuation principles and practice. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. ...

A mutual fund trust ☐ An executed copy of the trust document under which the trust operates is attached; and ☐ the applicant meets the requirements of Section 4801 of the Income Tax Regulation. ... A mutual fund corporation ☐ The applicant meets the requirements of subsection 131(8). ... An Investment corporation ☐ The applicant meets the requirements of paragraph 130(3)(a). ...

Before concluding that the supply of the service would be in New Brunswick, CRA stated: A service and real property would generally be regarded as being in relation to each other pursuant to the above guidelines if the purpose of the service is to: • physically count the property; • appraise or value the property; • physically protect or secure the property; or • enhance the value of the property. ...