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“Consultation on Reforming and Modernizing Canada's Transfer Pricing Rules” 6 June 2023-- summary under Subsection 247(1.3) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(1.3) The profit allocations that were accepted in Cameco were reached based on relationships created by intra-group contractual arrangements, notwithstanding Cameco Switzerland's minimal factual substance and Cameco Canada's assumption of related risks through the provision of performance guarantees to Cameco Switzerland – so that Cameco Switzerland was left with an allocation of income that did not correspond to the value it created through its underlying economic activity. ... Similarly, it would have retained some autonomy as to the disposition of its product over time. … [T]he overall result of the application of proposed subsection [247](2.02) would be the recognition by Canco of significant additional income in line with its functional profile …. ...

IT-273R2, "Government Assistance- General Comments," para. 15-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) Timing of recceipt of benefit of tax credit ¶ 17. Federal and provincial tax credits and deductions from tax which are in the nature of inducements, or which are received as assistance for the cost of property or an expense, are included in income under paragraph 12(1)(x) in the year received unless one of the exceptions discussed in ¶ 8 applies. ...

Amounts in Cdn$/functional currency Table 1 – Overview of allocation of income, taxes and business activities by jurisdictions For electronic filing, all amounts must be stated in Canadian dollars [except that]... ... The reporting entity discloses in Table 3 – Additional Information that it is reporting in one of the qualifying currencies notwithstanding that no election has been made by the reporting entity pursuant to paragraph 261(3)(b) of the Act. ... Payments received from other CEs that are treated as dividends in the payor’s tax jurisdiction should be excluded. … “Revenues-Related Party” should be read as the aggregate amount of revenues generated from transactions between constituent entities listed in Table 2, for each relevant tax jurisdiction. ...

Revenu Quebec "Place of Supply"-- summary under Subsection 6(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(1) The place of supply determines whether the HST or the GST and QST apply....For more information on the application of the GST/HST, refer to GST/HST technical information bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province, published by the Canada Revenue Agency. ...

This is reinforced in Coopers & Lybrand Ltd. v Bank of Montreal [1993] G.S.T.C. 36…at paragraph 38: …The assessment itself, does nothing other than provide information to the debtor. ...

Whether the Court’s decision in Medallion … would apply to another situation would require examination of all the relevant facts and documents. ...

Underused Housing Tax Notice UHTN2 Calculating the Underused Housing Tax Payable January 2023-- summary under Taxable Value Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Taxable Value Assessed value should be used if higher than value to which property tax is applied Assessed value established by an authority … A property assessment notice (or similar document) and a property tax bill are generally two separate and distinct documents. ...

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"-- summary under Specified Arm's Length Supply Summary Under Tax Topics- Excise Tax Act- Section 217- Specified Arm's Length Supply Example of specified non-arm’s length supply Qualifying consideration- Permitted deduction … For example, a qualifying taxpayer that is a non-resident FI incurred an expense for an insurance premium for property outside Canada used in part in respect of its Canadian branch. ...

T4068(E) Guide for the Partnership Information Return (T5013 Forms)-- summary under Subsection 96(4) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(4) Filing deadline for tiered partnerships references the “end” members Chapter 4 – Due dates Annual return The due date for filing an annual return (including distributing the T5013 slips) depends on the type of partners, including end members of a tiered partnership. ...

. … Time of filing A return or rebate application sent by first class mail or its equivalent is deemed by subsection 334(1) of the Act to have been received, and therefore filed, on the day it was mailed. ...