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Transactions – Scenario 3 (Copthorne-style transaction) Foreign Parent holds all the common shares of Canco with an FMV of $200 million and an ACB and PUC of $100 million, and Canco wholly owns Subco whose common shares have an FMV and ACB of $2 million and $40 million. ... Transactions – Scenario 1 (postponement of 21 st anniversary through s. 107(2) distribution to Canco held by new trust) Canco, which is wholly owned by a newly established discretionary resident trust (New Trust), is or will become a beneficiary of Old Trust, which is approaching its 21 st anniversary. ... Transactions – Scenario 2 (postponement of 21 st anniversary through s. 107(2) distribution to Canco held by non-resident beneficiaries of old trust) Canco, which is wholly owned by the non-resident beneficiaries of Old Trust, is or will become a beneficiary of Old Trust (which is approaching its 21 st anniversary). ...

Your taxable revenues and expenses are as follows: Taxable revenues: Gallery admissions $20,000 Sales from gift shop $5,000 Total $25,000 GST collected ($25,000 × 5%) $1,250 Taxable purchases: Contracted services (maintenance) $3,000 Utilities $1,500 Ventilation system $9,200 Computer equipment $2,000 Gift shop inventory purchases $2,500 Catering services for fundraising dinner $3,500 Total $21,700 GST paid on purchases ($21,700 × 5%) $1,085 Net tax calculation Step 1 Enter $750 on line 105 of your GST/HST return (60% of the $1,250 GST collected). ... ITC 5% × ($9,200 + $2,000) = $560 Step 3 The amount you calculate in Step 1 less the amount you calculated in Step 2 equals your net tax before any rebates. Net tax $750 – $560 = $190 Enter this amount on line 109. You would also be entitled to claim a PSB rebate of the remaining GST/HST paid. ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...