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In rejecting the Association’s submission that it collected its fees as Society membership dues as agent for the Society notwithstanding a statement in the Society’s by-laws that: “On behalf of the Society membership, […] [Districts, such as the Association,] shall pay to the Society an annual fee based on a per capita rate for each of its […] Members,” CRA confirmed its statements in a previous ruling letter to the Association that: [T]he bylaws of the [Society] provide no liability to the individual members to pay membership dues to [Society]. In particular, pursuant to section […] of the [Society]’s bylaws, the [District] organizations have the obligation to pay an annual fee to the [Society]. Although the amount of this fee is calculated based on the number of individual members, the individual members are not liable to pay this fee to the [Society]. … Therefore, the value of the consideration for [the Association]’s supplies of memberships is the entire amount charged by [the Association] to the individual members. ...

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed A proposed GST/HST amendment would zero-rate the supply of an ovum – which would have the effect of rendering the importation of an ovum as a non‑taxable importation. ... Respecting the application of the ovum amendment, for example, CRA indicates: [S]uppliers can stop charging GST/HST on supplies of human ova in accordance with the proposed amendment as of March 20, 2019. … [C]onsistent with its standard practice, the CRA is administering this measure on the basis of the proposed amendment [and similarly re … However, the CRA cannot pay a rebate for an amount paid in error as or on account of tax until the proposed amendment becomes law. A supplier who has charged or collected GST/HST on human ova supplied after March 19, 2019, must include that amount in the calculation of their net tax on their GST/HST return …. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 13(4.1)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(4.1)- Paragraph 13(4.1)(b) Similar business categories 1.41 …[T]wo businesses will be considered to be similar if they both fall within the same one of the following categories: merchandising- retailing and wholesaling; farming; fishing; forestry and forest products; extractive industries, including refining; financial services; communications; transportation; construction, including subcontracting; and manufacturing and processing. 1.42 … [W]here a business falls into more than one, a similar business will be one that falls into any one of these categories in which the business operates. ... As a result, if the plywood plant is sold, any business that also falls under the forestry and forest products or manufacturing and processing categories will generally be considered a similar business …. 1.43 A taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a similar business. … Similar services businesses 1.44 Service industries, such as hotels, restaurants, repairs, professional services, barber and hairdressing shops, funeral parlours, laundries, real estate agencies, tourism, and entertainment, are not included in the general business categories referred to in ¶1.41, because most of these industries are too varied and different to permit categorization. … [S]imilar business will generally be interpreted in a reasonably broad manner. ...

Also describes how a corporate shareholder which files electronically is to provide the required information, and states that a letter filed by a taxpayer with a paper return should contain: ◦ written notification that the shareholder is electing to defer tax relating to the distribution of spin-off shares from a U.S. (or other foreign) corporation, including a description of both the original and spin-off shares; ◦ the number, cost amount otherwise determined, and fair market value of the client's original shares, both immediately before the distribution and after the distribution; and ◦ the number and fair market value of the spin-off shares immediately after distribution. ...

Where, upon completion of a course, documentation is provided that does not attest to the competence of an individual to practise or perform a trade or vocation but merely states that the individual has taken and passed the course, the course will not qualify for zero-rating under section 18 …. ... Corporation Tree-NB invoices the non-resident company and not the employee. … While stand-alone industry safety courses may be beneficial, and in some cases a job requirement, on their own they would not be considered to lead to an occupation. As the course offered by Corporation Tree-NB does not lead to a diploma or certificate attesting to the competence of the individual to practice a trade or vocation, the course is not zero-rated under section 18 …. ...

. … The relevance of the timing of when a supply is made under section 133 to the application of section 144 is reflected in the wording of the definition of "specified supply" of goods under subsection 178.8(1) … [which] distinguishes between a supply of goods that are imported after the supply is made, and a supply of goods that have been imported in circumstances in which section 144 deems the supply to have been made outside Canada. … [S]hipments of fuel oil to CanCo commenced only after the agreement for the supply was reached …. ...

. …. The TCC determined that Zomaron delivered to the acquirer/processor fully negotiated merchants requiring card payment processing services. … The TCC determined the predominant element in respect of this single supply to be “arranging for” the card payment processing services offered by the acquirer/processor to the merchants and that this “arranging for” activity was a financial service. … Although a supplier may be registered as an ISO/MSP within the Visa/Mastercard networks, the supplier may not always perform the very same services and have the very same obligations and autonomy as another ISO/MSP. … The CRA will only apply the Zomaron decision to supplies made by an ISO/MSP if the same fact situation exists. ...

. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

. … Copper IUDs have a plastic frame that is wound around with copper wire or has copper sleeves. … [H]ormonal IUDs available in Canada contain the drug levonorgestrel which is on the list established under subsection 29.1(1) of the Food and Drugs Act and require a prescription from a physician to be purchased. … Therefore, the supply of hormonal IUDs is zero-rated pursuant to paragraph 2(b) of Part I of Schedule VI…. ...

. … No GST/HST collectible by CMHC on forgivable loans There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … ...