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. … In these circumstances, often the predominant element of the supply made by a downstream merchant is the provision of a licence in respect of real property (that is, providing space or a location for the ABM). This is a taxable supply. … Where the predominant element of the supply consists of replenishing money, providing telephone lines, electricity or any combination thereof, the supply would also generally constitute a taxable supply. ...

. … 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. ...

18 May 2018 Interpretation 183321-- summary under Subparagraph 174(a)(iv) Summary Under Tax Topics- Excise Tax Act- Section 174- Paragraph 174(a)- Subparagraph 174(a)(iv) allowance recognized even though subsequently donated back to charity Some of the volunteers at a registered charity are reimbursed for their expenses, or receive an allowance – but then donate those payments to the charity for a donation receipt. ... Accordingly, the expenses claimed by the charity for public service body (PSB) rebate purposes include the expenses recognized under ETA s. 175 or 174 as a result of its having paid the reimbursements or allowances – notwithstanding that those expenses in effect are donated back to it. ...

. … Appeal of adverse designation decision 2.6. An organization that does not meet the criteria for QCJO designation will also receive a letter from the CRA confirming the decision. … If the original decision does not change, the organization may apply for judicial review of the decision to the Federal Court of Canada. ...

. … Further, the prohibition on both "direct and indirect" partisan political activities is highly subjective (particularly "indirect"), and has been the subject of much confusion in the charitable sector…. ... Proposed amendment allowing charities to fully engage in non-partisan public policy dialogue and development that is subordinate to and furthers their charitable purposes (pp. 17-18) Recommendation 3 …The Panel recommends that amendments: retain the current legal requirement that charities must be constituted and operated exclusively for charitable purposes, and that political purposes are not charitable purposes; fully support the engagement of charities in non-partisan public policy dialogue and development in furtherance of charitable purposes, retiring the term "political activities" … and clearly articulating the meaning of "public policy dialogue and development" to include: providing information, research, opinions, advocacy, mobilizing others, representation, providing forums and convening discussions; and retain the prohibition on charities’ engaging in "partisan political activities", with the inclusion of "elected officials" (i.e. charities may not directly support "a political party, elected official or candidate for public office"), and the removal of the prohibition on "indirect" support, given its subjectivity. … The rationale for this approach is more fully described under Recommendation 1 in the context of interim changes recommended to the policy guidance. ...

CRA responded: Pursuant to … Polygon, Builder’s supplies are characterized as taxable supplies that are outside the scope of section 191 …. …[B]ecause Builder does not make (or hold the lots for the purposes of making) exempt supplies included in section 6 or 7 of Part I of Schedule V …, DeveloperCo’s subleases of the lots to Builder are exempt under subparagraph 7(a)(ii) of Part I of Schedule V as opposed to being exempt under section 6.1 of Part I of Schedule V. ...

. … Causal allocation 46. Causal allocation directly approximates the use of a particular business input using a logical and systematic approach and an appropriate allocation base. 47. ... An input-based allocation uses a calculation based on the procurative extent of other business inputs. … 51. ... Further, other distorting factors must be excluded from the ITC calculations in a revenue‑based method …. ...

. … When the vendor does not have to charge tax A different rule applies for used goods you accept as a trade-in from a person who is not required to charge GST/HST (usually a person who is not required to register for GST/HST). ... In this case, you generally charge GST/HST on the net amount of the sale or lease, that is, the price of the goods you sell or lease minus the amount you allow for the trade-in. … [S]ee GST/HST Technical Information Bulletin B-084, Treatment of Used Goods. ...

. … If the company's responsibility is limited to providing registered or licensed nurses to the facility so that the facility may satisfy its own staffing requirements, and the nurses are subject to the control of the operator of the facility and render services under the direction of the facility in accordance with the facility's responsibility to provide care to a patient or resident of the facility, the company has made a taxable supply of personnel or human resources, and not a supply of exempt nursing services. … However, if the company is responsible for the provision of nursing services to the patients or residents of the facility and is accountable for the quality of nursing care provided, the company may have made an exempt supply of a nursing service rendered by a registered or licensed nurse to an individual, where the service is provided within a nurse-patient relationship. ...

Effecting repatriation Repatriation can be accomplished by: offsetting inter-company accounts receivable from the non-resident – It should be remembered that this method of repatriation might have an effect on other items. For example, interest charges may have to be adjusted on a going-forward basis to reflect the revised inter-company balances; the transfer of money or its equivalent to the non-resident corporation; where a Canadian parent company cannot otherwise effect repatriation within a reasonable time, the creation of a shareholders loan account – This would be effective at the date of the transfer pricing transaction and may result in the application of subsection 15(2) of the Act; or netting upward and downward transfer pricing adjustments from different non-residents if both the taxpayer and all the non-residents involved agree in writing to have the amounts offset.... ...