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. … [C]onsistent with its standard practice, the CRA is administering this measure on the basis of the proposed amendment [and similarly re embryos] If the proposed amendment becomes law, you may then contact the supplier, who may choose to adjust the amount charged, or refund or credit the amount collected. ... Alternatively, you can file a rebate claim with the CRA for the amount paid in error …. ...

Does the stipulation in s. 90(9)(b), that the exempt surplus must be “not relevant in applying this subsection in respect of... any deduction under subsection... 113(1) in respect of a dividend paid, during the period in which the particular loan … is outstanding” signify that Canco could not access the s. 90(9) deductions in years 1 to 3, because the loan was still outstanding in year 4 at the time that the dividend was paid out of exempt surplus? ... …[T]he CRA would not deny the deduction under subsection 90(9) in years 1, 2, and 3 as a result of the claiming of the subsection 113(1) deduction by Canco in year 4 …. ...

. … Mortgage broker as example of non-qualifying institution Example 4 Insurance Broker D is an insurance broker during its fiscal year ending December 31, 2019. ... As a result, if a financial institution (other than certain new corporations formed as the result of a merger or amalgamation) did not exist for two years prior to the particular fiscal year, the financial institution would not be a qualifying institution for that particular fiscal year. … 12. ...

. … If A and B are not builders of a residential complex because of paragraph (f) of the definition of “builder” … they will not be subject to the self-supply rules in any of subsections 191(1) to (4), and accordingly, they will not be subject to the personal use exception in subsection 191(5). ...

For example … a corporation could be a builder of a residential complex under subparagraph (b)(ii) where the corporation is a developer-landlord who purchases an apartment building that is under construction, and finishes the construction, for the primary purpose of leasing the apartment units to tenants. ... [emphasis in original] … [A] corporation that is a purchaser-landlord who acquires a right to purchase an apartment building that is under construction for the primary purpose of leasing the completed apartment building to another person under a head lease (or for the primary purpose of leasing the completed apartment units to tenants) would not be a paragraph (b) builder because of the exclusion in paragraph (h). ...

. … If a particular method accurately reflects the purpose for which the property or service was acquired, the method would be fair and reasonable. ... If the public institution claimed ITCs based on the purpose for which it acquired its inputs it would claim ITCs equivalent to 2.18% (2% + 0.18%) of the tax paid or payable on all taxable inputs based on: 2% of taxable inputs are for use exclusively for the purpose of making taxable supplies for consideration; 88% of taxable inputs are for use exclusively for the purpose of making exempt supplies; and 10% of taxable inputs are for use both for the purpose of making taxable supplies for consideration and for either the purpose of making exempt supplies or for a purpose other than making supplies: 85% of the mixed-use inputs are for use less than 10% in commercial activities and are not eligible for ITCs; 15% of the mixed-use inputs are for use 12% for the purpose of making taxable supplies for consideration and 88% for the purpose of making exempt supplies and for purposes other than making supplies....If a revenue-based ITC allocation method is appropriate in the circumstances, excluding the government funding revenue from the denominator in the calculation would not be fair and reasonable because government funding may be the greatest source of revenue for the public institution and that revenue is used to purchase inputs, including taxable inputs that are used in making exempt supplies. ...

Partnership and partner are separate persons for replacement property purposes 1.53 The replacement property rules would … apply to a member of a partnership who acquires a replacement property for a personally owned former business property which is or was being used in the partnership business. ... Application to non-residents 1.56 The replacement property rules can apply to a non-resident who has disposed of taxable Canadian property and who acquires a qualifying replacement property that is also taxable Canadian property …. ...

… Separation of legal and beneficial ownership Ordinarily, a person who has legal title to a property also has the ability to use, enjoy and “benefit from” the property. ... The beneficiaries have rights against the trustees to enforce the terms of the trust. … Trust vs. agency and bare trusts Trust relationships are distinct from agency relationships, even though both trustees and agents act on behalf of other persons. ...

30 April 1999 Technical Interpretation RITS HQR001701-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) "... ...

.- Q. 27-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Foreign travel expenditures, including remuneration, will generally be allowed if they are directly attributable to R & D carried on in Canada. ...