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This requirement … is outlined in … “Protocole D’entente” signed August 30, 1990 between the CRA and RQ. … [S]ection 4.1 … states: Canada and Quebec recognize that, with respect to the transfer to Quebec of administrative responsibilities of the GST, they will continue to assume their duties under the Official Languages Act and the Charter of the French Language respectively, with respect to communications with the public, including corporations and the services provided to them. … [S]ection 4.2 … states: … Quebec declares that, subject to the provisions of the Charter of the French Language, it will communicate with taxpayers in the administration of the GST, either orally or in writing, in English or French, to the same extent that such taxpayers may communicate with or receive services from Canada in those languages in accordance with the Official Languages Act. ...

The gymnasium becomes a place of amusement during the exhibition as defined in the first category (“any … place … which is staged or held any … artistic … exhibition”). ... The church building is a place of amusement during the concert… (“any … place … at or in any part of which is staged or held any … musical or other performance, …”). ... The skating rink is a place of amusement… (“any place … the purpose of which is to provide any type of amusement or recreation”). …[]As] one of the admission prices is more than $1…all the supplies of admissions, regardless of price, are subject to GST/HST. ...

RC312 Reportable Transaction Information Return (2011 and later tax years)-- summary under Subsection 237.3(2) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(2) Part 9 – Detailed description of all the facts of the transaction and tax consequences Describe the reportable transaction in chronological order including, but not limited to, the following: the nature of the expected tax treatment and the tax consequences; a description of the tax benefit sought; the parties involved and each party's role, responsibilities and obligations; the legislative provisions that apply and how they allow the taxpayer to obtain the desired tax treatment; and any other relevant information. If the transaction is part of a series of transactions, describe each transaction in the series and identify which one is an avoidance transaction. … Part 10 – Steps and tax consequences to come Describe any remaining steps required to complete the transaction and their related tax consequences. Include the same type of information as that requested in Part 9. … Part 11 – Amount of the tax benefit or the impact on income Enter in each column the actual or estimated amount of the tax benefit resulting from the reportable transaction, or the amount of the reportable transaction's actual or estimated impact on income, for each of the periods listed in the left-hand column. ...

Transactions – Scenario 3 (Copthorne-style transaction) Foreign Parent holds all the common shares of Canco with an FMV of $200 million and an ACB and PUC of $100 million, and Canco wholly owns Subco whose common shares have an FMV and ACB of $2 million and $40 million. ... Transactions – Scenario 1 (postponement of 21 st anniversary through s. 107(2) distribution to Canco held by new trust) Canco, which is wholly owned by a newly established discretionary resident trust (New Trust), is or will become a beneficiary of Old Trust, which is approaching its 21 st anniversary. ... Transactions – Scenario 2 (postponement of 21 st anniversary through s. 107(2) distribution to Canco held by non-resident beneficiaries of old trust) Canco, which is wholly owned by the non-resident beneficiaries of Old Trust, is or will become a beneficiary of Old Trust (which is approaching its 21 st anniversary). ...

Your taxable revenues and expenses are as follows: Taxable revenues: Gallery admissions $20,000 Sales from gift shop $5,000 Total $25,000 GST collected ($25,000 × 5%) $1,250 Taxable purchases: Contracted services (maintenance) $3,000 Utilities $1,500 Ventilation system $9,200 Computer equipment $2,000 Gift shop inventory purchases $2,500 Catering services for fundraising dinner $3,500 Total $21,700 GST paid on purchases ($21,700 × 5%) $1,085 Net tax calculation Step 1 Enter $750 on line 105 of your GST/HST return (60% of the $1,250 GST collected). ... ITC 5% × ($9,200 + $2,000) = $560 Step 3 The amount you calculate in Step 1 less the amount you calculated in Step 2 equals your net tax before any rebates. Net tax $750 – $560 = $190 Enter this amount on line 109. You would also be entitled to claim a PSB rebate of the remaining GST/HST paid. ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...

. … [A] complete list of these group members must be attached to the joint election. … … This election … and the list, must be made and retained with the eligible employer's other books and records …. ...

In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ... Interest will be adjusted consequentially …. These transfer pricing principles will also apply to all taxation years after 2010, including the 2011 to 2015 taxation years which are currently under audit and on a go forward basis [as to transfer pricing matters under current law]. ...

… Once an eligible employer has determined that it has experienced the required reduction in revenue for a particular claim period, it is automatically considered to have experienced the required reduction in revenue for the immediately following claim period (deeming rule). As a result, the employer does not have to make this determination again for that next claim period …. … In a situation where the eligible employer, subsequently determines that it actually experienced the required reduction in revenue, without applying the deeming rule, for the second claim period- April 12 to May 9, 2020, the eligible employer will be considered to have experienced the required reduction in revenue for that third claim period because of the deeming rule that can now be applied to the third period …. ...