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GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014-- summary under Section 15.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 15.1 62. ...

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014-- summary under Section 6.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 6.1 Emergency 38. ...

CBAO National Commodity Tax, Customs and Trade Section – 2011 GST/HST Questions for Revenue Canada, Q. 5-- summary under Paragraph 8(b) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 8- Paragraph 8(b) supply of goodwill based on address of purchaser A Co is selling to B Co assets of a portion of its service/repair business which it carries on in Quebec and Ontario including goodwill (mostly, a customer list, valued at over $300). ...

International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation:The FATF Recommendations June 2017-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership FATF concept of "financial institution" (referenced by CRA in FATCA context) (pp. 116-7) Financial Institutions means any natural or legal person who conducts as a business one or more of the following activities or operations for or on behalf of a customer: 1. ...

Form RC4609E – Election or Revocation of Election to Use the Real-Time Calculation Method or the Reconciliation Method-- summary under Subsection 50(2) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 50- Subsection 50(2) Effect of election to use the reconciliation method Generally, a reconciliation method election allows an investment plan to elect to use its current year provincial attribution percentage for the purposes of the SAM formula. ...

2 December 2019 Comfort Letter- Cross-Border Surplus Stripping & Graduated Rate Estates-- summary under Paragraph 212.1(6)(b) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(6)- Paragraph 212.1(6)(b) relief for GREs, with non-resident beneficiaries, engaging in pipelines Finance first noted that in a pipeline transaction (entailing the estate selling the shares of Canco (whose ACB was stepped up on death) to a newco (NewCanco) for a note of NewCanco, which on its subsequent repayment, effectively extracts the corporate surplus of Canco), each non-resident estate beneficiary is deemed, after giving effect to the look-through rule in s. 212.1(6)(b), to their proportionate share of the promissory note, and will pay tax on the deemed dividend resulting from the excess of that beneficiary’s proportionate share of the promissory note over the paid-up capital of their proportionate interest in the Canco shares. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.3-- summary under Paragraph 211(5)(c) Summary Under Tax Topics- Excise Tax Act- Section 211- Subsection 211(5)- Paragraph 211(5)(c) CRA may accept a late-filed ETA s. 211 election A charity may be operating as if a s. 211 election has long since been filed for a property, but the CRA internal system does not show a s. 211 election and with staff changes and passage of time, the charity is not in a position to demonstrate its filing. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Reportable Transaction- Paragraph (a) Reportable Transactions Contingent fee arrangements A fee does not come within (a) of reportable transaction where: It is a standard fee (that is, generally available to the public under normal commercial terms and in comparable circumstances) by a financial institution is charged respecting listed matters. ...

GST/HST Memorandum 3-3-2, Place of Supply in a Province – Overview, August 2024-- summary under Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Service Description of distinction between supplies of IPP and services 46. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Clause 6(2)(b)(i)(B) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(2)- Paragraph 6(2)(b)- Subparagraph 6(2)(b)(i)- Clause 6(2)(b)(i)(B) Primacy generally accorded to the contracting address 50. ...