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Summary of 8 March 2018 CBA Roundtable, Q.23 under Deduction for Provincial Rebate (GST/HST) Regulations – Sched.1 – s. 1. ...

28 December 2018- 12:40am CRA indicates that the construction of a pipeline can qualify for the GST/HST joint venture election Email this Content The Joint Venture (GST/HST) Regulations provide that “the construction of real property … including … development activities” is eligible for the joint venture election. ...

Summary of 2024 Ruling 2024-1017941R3 under s. 66.1(6) – CEE – (f). ...

Summaries of 10 January 2018 Interpretation 139614 under ETA – s. 123(1) – financial service – para. ...

4 June 2018- 12:26am CRA references a checklist for determining indefeasible vesting Email this Content For purposes of the 21-year deemed disposition rule, a trust does not include a trust "all interests in which … have vested indefeasibly". ... Summary of 29 May 2018 STEP Roundtable, Q.9 under s. 108(1) – trust – (g). ...

Respecting whether the circuit was a fixed place of business of FOWC, he did not appear to attach much significance to the assignment by FOWC to its affiliates of various rights, stating: … The … arrangement clearly demonstrates that the entire event is taken over and controlled by FOWC and its affiliates. ... Respecting whether the circuit was “permanent” notwithstanding the three-day duration of the annual races, he stated (adopting, as indicated, reasons below): [B]oth the exclusive nature of the access and the [up to 6-week] period for which it is accessed…makes the presence of a kind contemplated under Article 5(1), i.e. it is fixed. … [T]he OECD commentary and Klaus Vogel 's commentary…[state] that as long as the presence is in a physically defined geographical area, permanence in such fixed place could be relative having regard to the nature of the business…. ... Commissioner of Income Tax, International Taxation – 3, Delhi & Anr., Civil Appeal No. 3849 of 2017 under Treaties- Article 5. ...

Summary of OneREIT Circular under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – REIT Mergers. ...

27 September 2020- 11:17pm CRA rules on qualification of a seniors facility for the 83% GST rebate Email this Content One of the requirements for the receipt of the 83% GST rebate by a registered charity operating a nursing home was that (under (a)(iii)(B) of the definition of “facility supply”) “a physician … be at, or be on call to attend at, the … qualifying facility at all times when the individual is at the … qualifying facility.” ... Summary of 6 July 2020 GST/HST Ruling 123293 under ETA s. 259(1) – facility supply – (a)(iii)(B). ...

Those who want to retain the High Yield Fund units will not have those units redeemed, so that they only receive cash for their REIT units – and in effect receive their High Yield Fund units on a tax-deferred basis. ... Summary of Northview Apartment REIT Circular under Mergers & Acquisitions – REIT/Income Fund /LP Acquisitions – LP Acquisitions of Trusts. ...

[B]ased on George Weston … a compelling argument can be made that gains and losses resulting from a dynamic hedging strategy to hedge a capital asset should also be on capital account despite the fact that there may be numerous transactions. … [T]he relevant issue is the character of the risk that is being hedged (depreciation in value of a foreign-currency-denominated capital asset), not the number of transactions. ... Taylor, "Taxation of Hedges and Derivatives: Recent Developments," 2016 Conference Report (Canadian Tax Foundation), 13:1-36 under s. 9- timing, s. 9 – capital gain v. profit – futures/forwards/hedges, and s. 248(1) – derivative forward agreement – s. ...