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CRA indicated that: … [N]o information will be released to the police or other law enforcement agencies without the approval of the Assistant Commissioner of the Compliance Programs Branch. … Since enactment in June 2014, the CRA has not exercised its authority under the new legislation. ...

GST/HST Memorandum 17-11 [17.11] Determining Whether a Financial Institution is a Qualifying Institution for Purposes of Section 141.02 23 July 2021-- summary under Residual Input Tax Amount Summary Under Tax Topics- Excise Tax Act- Section 141.02- Subsection 141.02(1)- Residual Input Tax Amount SLFIs only account for federal tax in residual input tax amount 16 … [T]hese provisions [in para. ... (b)] include the federal, but not the provincial, part of the HST …. ...

. … If there is no transfer of ownership of a particular property, we do not consider a supplier to have sold, and a recipient to have purchased, the property. … Accordingly, property leased from a lessor is generally not considered to have been acquired for income tax purposes and, as such, is not treated as capital property for purposes of the ITA or, by extension, the ETA. ... Therefore, property leased from a third party will not be considered to be capital property for GST/HST purposes, regardless of whether the lessee and the lessor have made an election under subsection 16.1(1) …. ...

. … With respect to other adjustments for amounts that the vendor has paid or collected and that relate to the period during which time the purchaser will be the owner of the real property, it is a question of fact as to whether the adjustments increase or decrease the value of consideration for the sale of the real property. … [I]f an obligation is inextricably tied to the real property itself, then it is likely not a separate supply from the sale of the real property and the adjustment likely increases or decreases the value of consideration, as the case may be. Conversely, if it is determined that an obligation giving rise to the adjustment is a separate supply from the sale of the real property that is not incidental to the sale of the real property, then the application of the GST/HST to the adjustment depends on the nature of the separate supply itself. … With respect to any adjustment described above that is made post-closing (that is, made after the transaction has been finalized and the purchaser has paid the balance owing to the vendor), the application of the GST/HST to the adjustment would be as described above. ...

. … Where, under a stock option agreement, an employer elects to pay cash in lieu of issuing shares, subsection 7(1) does not apply and the amount of cash received by the employee is taxable under either subsection 5(1) or paragraph 6(1)(a)…. Where it is the employee who has the right to choose cash instead of shares, paragraph 7(1)(b) will apply, in respect of the cash received by the employee in satisfaction of the employee's rights under the plan. … ...

. … [W]here the CSA represents a type of an agency relationship or a mandate for the employers, each of the separate eligible employers may qualify for the wage subsidy in respect of their portion of eligible remuneration paid to each eligible employee by the agent or the mandatary in respect of a week in a claim period, as long as all of the other eligibility criteria have been met …. Only the actual employer(s) can apply for the wage subsidy in respect of a particular employee …. ... New: October 6, 2020 [The] case law, which generally describes a joint venture as a limited business undertaking by two or more parties, in which the parties have a joint property interest in the subject matter of the venture and share control and management of the enterprise. … A joint venture is not an eligible employer for the purposes of the wage subsidy. ...

Required information in the election The CRA is expanding the amount of information a taxpayer must provide with their election in order for it to be considered valid. … New information requested includes: Identification of the first taxation year in respect of which this PLOI election is to be made, the total amount owing initially and the currency in which it is denominated. ... A declaration as to which of the two interest rates applies to the PLOI: the amount computed at the prescribed rate applicable; or where the PLOI is funded directly or indirectly by another interest-bearing loan or indebtedness, the amount of interest payable by the CRIC on that other loan. … 2. ... This policy is also applicable in the determination of any late-filing penalty that may be applicable in respect of a PLOI election. … Retroactive relief for late-filed penalties in respect of revolving balance loans The CRA is adopting an administrative position to apply the above described late-filed penalties relief retroactively. ...

. … One of the characteristics of a joint venture is that the participants have a right of mutual control. … Essential strategic and major decisions such as disposition of assets and large expenditures normally require consent of all the participants. ...

. … [N]o information will be released to the police or other law enforcement agencies without the approval of the Assistant Commissioner of the Compliance Programs Branch. … Since enactment in June 2014, the CRA has not exercised its authority under the new legislation. ...

14 October 2016 Interpretation 170549-- summary under Paragraph 240(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(3)- Paragraph 240(3)(a) nominee accepted as registrant ACo and BCo, which were co-tenants of a property in construction held through a Nominee made a s. 273 election in year X + 2 designating ACo as the operator. At the same time as making this election ACo and BCo also signed an agency agreement in which Nominee was designated as the agent of ACo and BCo and which provided that the Nominee was the authorized agent and representative of ACo and BCo including for the claiming of input tax credits – and the Nominee made such claims prior to the end of the period of administrative tolerance expressed in GST/HST Notice 284. ...