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Administrative Policy summary

May 2013 ICAA Roundtable, Q. 18 (reported in April 2014 Member Advisory) -- summary under Paragraph 118.2(3)(b)

. For this reason, one is to assume that the expenses would need to be submitted to the insurance company before the amount can be considered by the Canada Revenue Agency…. ...
Administrative Policy summary

Memorandum (New Series) 17.7 De Minimis Financial Institutions (aka 17-7) February 2013 -- summary under Paragraph 149(1)(c)

. [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...
Administrative Policy summary

Eligible spin-offs -- summary under Subsection 86.1(2)

Eligible spin-offs-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) // www.cra-arc.gc.ca/tx/bsnss/tpcs/frgncrp-eng.html ">"Information for foreign corporations" 6 March 2012: Respecting the requirement in s. 86.1(2)(b) that the distribution consist only of shares, CRA states: If the shares distributed in the course of the spin-off had rights to purchase other shares attached to them, the corporation should confirm that the rights plan was established for bona fide business purposes other than to obtain a tax benefit. ...
Administrative Policy summary

26 February 2015 CBA Roundtable, Q.21 -- summary under Qualifying Member

26 February 2015 CBA Roundtable, Q.21-- summary under Qualifying Member Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Member s. 186(1) does not deem use of property in commercial activity CRA indicated that s. 186(1) applied “only for the purpose of ITC calculations” and does not have the effect of deeming the holding company to be engaged in commercial activity so that it would generally not qualify for the purposes of making a s. 156 election with a subsidiary so as to avoid having to charge GST on management fees. ...
Administrative Policy summary

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017 -- summary under Section 13

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Section 13 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations, No. 2- Section 13 Public service body acquiring software programming services for use in two provinces Example 7 references a PSB that is charged at the Ontario rate of 13% on software programming services acquired by it for “use” 80% at its Ontario head office and 20% at one of its offices in PEI and goes on to note that the PSB would be required to self-assess itself for the 2% higher PEI HST rate on the 20% portion for use in PEI, before then calculating its s. 259 rebate. ...
Administrative Policy summary

GST New Memorandum 8.1, ITCs—General Eligibility Rules, May 2005 -- summary under Subsection 169(1)

. The person that is eligible to claim the ITC for the tax paid or payable on the property or service is usually the recipient. ...
Administrative Policy summary

23 May 2017 Interpretation 182665 -- summary under Paragraph 254(4)(c)

CRA stated: We confirm that an electronic signature produced using […] or [a] similar device is acceptable for purposes of filing a GST/HST rebate application, provided the signature and any related electronic records exhibit the characteristics of reliability, integrity, and authenticity, as discussed in GST/HST Memorandum 15.2, Computerized Records. ...
Administrative Policy summary

2 August 2017 Ruling 182285 -- summary under Consideration

CRA ruled that the rebate is financial assistance and does not reduce the consideration for the supply of the electricity so that input tax credits or public service body rebate claims of the recipient are not reduced by the rebate amount. ...
Administrative Policy summary

8 March 2018 CBA Commodity Tax Roundtable, Q.13 -- summary under Paragraph 157(1)(b)

8 March 2018 CBA Commodity Tax Roundtable, Q.13-- summary under Paragraph 157(1)(b) Summary Under Tax Topics- Income Tax Act- Section 157- Subsection 157(1)- Paragraph 157(1)(b) wire transfers can get lost because of intermediary banks cutting off essential characters CRA observed that because “intermediary banks often have a limit on the number of characters allowed in [a wire transfer] transaction, so this can result in some essential information being cut off” thereby resulting in difficulties allocating payments from non-residents and others to the correct account and stated that “Currently, the best way to ensure that a wire transfer is successful is to also send a fax with the account information.” ...
Administrative Policy summary

25 June 2018 Ruling 143194 -- summary under Section 10

Association of Kinesiologists, who provided various treatments to patients, that “as kinesiology services are not listed in the Health Care Services (GST/HST) Regulations they are not exempt from GST/HST under section 10 of Part II of Schedule V.” ...

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