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. … Consequently … SENC could elect, under subsection 1103(1), to include in Class 1 of Schedule II, the properties in Classes 8 and 10, but could not include those covered by the election under subsection 1101(5b.1). ...

Summary of 15 June 2023 GST/HST Interpretation 222419 under ETA s. 123(1) – municipality – (b) and Sched. ...

Summaries of 8 January 2025 Internal T.I. 2024-1032871I7 under Reg. 100(1) – remuneration – (b.1) and s. 56(1)(x). ...

Summary of 23 January 2025 External T.I. 2024-1030091E5 under s. 125(7) – SCI – (a)(i)(B). ...

Summary of 28 March 2025 External T.I. 2016-0662951E5 F under s. 110.6(1) – QSBCS – (b). ...

(c) of the definition of “excluded entity” in s. 18.2 is that “all or substantially all of the businesses … and undertakings and activities of the taxpayer are … carried on in Canada.” ... Summary of 3 December 2024 CTF Roundtable, Q.4 under s. 18.2(1) – excluded entity – (c)(i). ...

. … Arguably, the threshold in, for example, Prévost Car, and Alta Energy may be insufficient. More generally: [T]here will be less risk of challenge under the PPT if there are demonstrable reasons for having a presence in a particular jurisdiction (such as key decision makers located in the jurisdiction, commercial or other regulatory reasons, proximity to jurisdictions into which investments are made, etc.) …. ... Summary of Nelson Whitmore and Owen Strychun, “Canadian Inbound Investment After the MLI,” Canadian Tax Journal, (2019) 67:3, 831-80 under Treaties – MLI – Art. 7(1). ...

19 July 2020- 10:44pm CRA considered that promotional services provided by a public sector body to a sponsor were not subject to GST/HST given the substantial advertising was not the main motivation [corrected link] Email this Content ETA s. 135 deem a supply by a public sector body (PSB) of a service, or a licence of copyright, a trade-mark, trade-name or other similar property to a “sponsor” for exclusive use by the sponsor in publicizing the sponsor’s business, to not be a supply – except that this rule is stated not to apply where the consideration for this supply by the PSB to the sponsor is “primarily” for radio, TV, newspaper, or magazine advertising. ... In explaining why the exclusion for TV advertising did not apply, CRA noted that in a previous file, it had concluded that even though “in monetary terms, the advertising represented a substantial part of the sponsorship, we considered that the reason a sponsor would want to sign an agreement and pay the funds was for the recognition of being a partner in the … events … and being able to use the logos associated with them.” In the current example, “the television advertising service is not the main reason why [the PSB] would want to sign the agreement. “ Neal Armstrong. ...

(f) effectively provides a further exemption regarding such an assignment where the assignor is an individual who is not engaged in an adventure in the nature of trade or a business – whereas ETA draft s. 192.1 will eliminate this exemption. Comments of CRA on the effects of this new rule include: Under the new rule, where the (post-May 22, 2022) assignment agreement indicates that a part of the consideration is attributable to the reimbursement of a deposit paid by the assignor to the builder under the subject purchase and sale agreement, that deposit amount is excluded from the taxable amount of the assignment – whereas under the old regime, if the assignment was taxable, the total consideration for the assignment- including any portion referable to the assignment of the deposit- was taxable. ... Summaries of GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022 under ETA s. 123(1) – builder – (d), s. 254(1)- single unit residential complex, s. 254(2)(i), s. 254(4), s. 256.2(3) and s. 192.1. ...

Summary of 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017, under s. 125(1) – specified corporate income – (a)(i), specified partnership income – (c). ...