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. … (e) The later accounting of the transactions by all parties is as if the election was made … 57. A request will not be accepted in the following cases: (a) It is reasonable to conclude that the taxpayer made the request for retroactive tax planning purposes. … (c) It is reasonable to conclude that the taxpayer had to make the request because he or she was negligent or careless to comply with the law ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

GST60 GST/HST Return for Purchase of Real Property or Carbon Emission Allowances-- summary under Paragraph 228(4)(b) Summary Under Tax Topics- Excise Tax Act- Section 228- Subsection 228(4)- Paragraph 228(4)(b) Use this return to report and pay the goods and services tax/harmonized sales tax (GST/HST) when you purchase taxable real property (for example, land or a building) or you purchase taxable supplies of emission allowances (see page 3 for definition) that are made in Canada, and you are in any of the following situations: • You are registered for the GST/HST and the use or supply of the real property or emission allowances in your commercial activities will be 50% or less. • You are not registered for the GST/HST and you purchased the real property from a person who is not resident in Canada, or from a person who is considered to be resident only for activities carried on through the person's permanent establishment in Canada. • You are not registered for the GST/HST and you purchased taxable supplies of emission allowances that are made in Canada ...

Calculation of Corporation X's qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Corporation Y: $100 x $400 (QR attributable to Corporation Y)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,000(Corporation Y QR for current reference period)/$1,500 (Corporation Y QR for prior reference period) = 19 QR calculation in relation to Corporation Z: $100 x $1,000 (QR attributable to Corporation Z)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,300(Corporation Z's QR for current reference period)/$2,000 (Corporation Z's QR for prior reference period) = 46 The weighted average qualifying revenue for Corporation X for the current reference period is $65 ($19+$46). ... Calculation of Canco’s qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Forco: $100 x $900 (QR attributable to Forco)/$900 (Canco total QR from non-arm’s-length persons or partnerships) x $1,500 (Forco QR for current reference period)/$2,000 (Forco QR for prior reference period) = 75 Since the prior reference period’s qualifying revenue is deemed to be $100, Canco has experienced the required reduction in revenue of at least 15% for the claim period. ... Meaning of “substantially all” Generally, the phrase “all or substantially all” means at least 90%. … However, the “all or substantially all” test could, depending on the circumstances and context, be satisfied even if the 90% level is not strictly achieved. ­­­­­­­­­­­­­­­­ ...

. … a location may not be a RPE for an individual if, for example, the individual works at that particular location only once during the year or perhaps for only a few days in the year. … The CRA’s general position is that travel between an employee’s home and their employer’s business location is personal, even when the employee has a home office that is a regular place of employment. … CRA does not have a list of common factors used to determine if a work location is an RPE. … [F]or a location to be considered a special work site…: 1. ...

. … The phrase any other purpose except profit is interpreted as a catch-all for other associations that are organized and operated for other than commercial or financial reasons. Permitted accumulation of funds for building replacement etc. 9. … [I]n certain cases, when an association requires a time period in excess of the current and prior year to accumulate the funds needed to acquire a capital property that will be used to achieve its declared exempt activities, the association's tax-exempt status may not be affected. ... Also included are payments made to employees or members of the association to assist them in covering their expenses to attend various conventions and meetings as delegates on behalf of the association, provided attendance at such conventions and meetings is to further the aims and objectives of the association. … ...

. … Currently, the profession of acupuncture is regulated under provincial legislation in the provinces of British Columbia, Alberta, Ontario, Quebec and Newfoundland and Labrador. If an acupuncture service is supplied in any of these provinces, the acupuncturist is required to be licensed by the regulatory body for the profession of acupuncture in that province in order to be a “practitioner” for GST/HST purposes (e.g., College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario). … [I]f an acupuncturist makes a supply of an acupuncture service in [other provinces]…the acupuncturist is required to have qualifications equivalent to those qualifications required to be licensed in a province where the profession is regulated…. Psychotherapy services Currently, there is no provision in the Act that specifically exempts from the GST/HST supplies of psychotherapy services or services rendered by a psychotherapist, even if the psychotherapist is licensed and renders the service in a province that regulates the profession of psychotherapy. … [S]upplies of psychotherapy services rendered to an individual by a licensed physician or registered nurse, social worker, psychologist or occupational therapist will be exempt from the GST/HST if the supply meets the requirements in the relevant exemption and the supply is also a qualifying health care supply…. ...

. … 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. ...

They are individually packaged and can be sold individually or in a box of [#]. CRA stated: When tobacco twists are imported but before they can be released into the duty paid market, The Act states they must be packaged in a package with prescribed information on it and be stamped. … If marketed as a single twist then the prescribed package as defined by the Stamping and Marking Regulations of Excise Act, 2001 would be the package containing the single twist. If marketed in the box of [#], the box would be the prescribed package as defined by the Regulations. ...