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Note: on the RC4649, the reporting entity is either: • the UPE • an SPE – a Canadian CE that has been designated as a surrogate parent of a foreign UPE. Note: A Canadian CE cannot be designated as an SPE of a Canadian UPE • a CE, in cases of a local filing requirement Filing obligations of Canadian CE that is SPE Obligations of a surrogate parent entity in Canada A CE resident in Canada that is appointed as an SPE of a foreign UPE is subject to filing requirements as if that entity were a UPE in Canada. In particular, subsection 233.8(1) of the Act defines an SPE as a CE of an MNE group that has been appointed by the MNE group — in substitution for the UPE — to file the CbC report on behalf of the MNE group, if one or more of the conditions in subparagraph 233.8(3)(b)(ii) applies (i.e., the conditions for the secondary reporting mechanism to apply). ...

. … In addition to the diploma program, the school offers 3 courses: “Enhancing Your Webpage with Java”, which is also a credit course in the diploma program [exempt] “Programming in C++”, which is offered as an upgrade program and for which students are graded on a mid term assignment and final exam [exempt] “Supporting and Implementing Windows”, which is not offered as part of the diploma program and for which students are evaluated based on class attendance and participation Certificates are issued to students upon completion of each of the courses. … … [T]he supply of instruction in “Supporting and Implementing Windows” is not exempt under section 8 of Part III of Schedule V, regardless of the fact that a certificate is issued upon successful completion of the course. ... The CRA does not consider an individual to be under instruction and direct supervision while amassing build-up flight time hours. … 55. Where a student purchases hours of dual or solo flight time over and above the minimum time requirements in the federal legislation, the supply of the additional hours is not exempt under section 8 …. 56. ...

IT-170R "Sale of Property- When Included in Income Computation"-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (e) Dispositions reference changes of beneficial ownership ¶ 4. Subparagraph 54(c)(v) [similar to what now is s. 248(1) – disposition – para. ...

. … "Rent-to-own" vs "sale" Policy statement P-164 … 16. … Because the self-supply rules apply only where there is a supply by way of lease, licence or similar arrangement, it is necessary to determine if a rent-to-own agreement represents a supply by way of sale or a supply by way of lease, licence or similar arrangement. ...

May 2017 CPA Alberta Roundtable, GST/HST Q.3-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) construction of fixture qualifies The construction of a pipeline likely would qualify as “the construction of real property … including … development activities” under the Joint Venture (GST/HST) Regulations “to the extent that it is affixed to the ground and intended to remain there on a permanent basis.” ...

. … The following are apportionment methods we consider to be reasonable. Liability apportionment – prorated to earnings This method apportions the liabilities based on each participating employer’s share of a member’s lifetime retirement benefits. If a member receives pensionable earnings (compensation) from multiple participating employers in the year, the actuary must use those pensionable earnings to prorate the accrued lifetime retirement benefit (LRB) and DB limit in the year. … Asset apportionment – prorated to liabilities This method apportions the assets in proportion to the liabilities allocated to each participating employer using the pensionable earnings. ...

Statement by the Minister of National Revenue and Minister of Finance on the Government’s Commitment to Clarifying the Rules Governing the Political Activities of Charities 15 August 2018 Press Release-- summary under Subsection 149.1(6.2) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(6.2) … Canada Without Poverty … [contains] significant errors of law and … will be appeal[ed] … to address the uncertainty created by it, and to seek clarification on important issues of constitutional and charity law. … [O]ur Government intends to amend the Income Tax Act to implement changes consistent with recommendation no. 3 of the Report of the Consultation Panel on the Political Activities of Charities. ...

Example 11 – Adjustment to net tax for rental property on becoming a small supplier division In July, a registrant PSB resident in Ontario that has a monthly reporting period prepays the monthly rent of $1,500 plus HST for six months (July through to December) for the building in Ontario used by its division in commercial activities. The total amount of rent prepaid is $9,000 ($1,500 × 6 months) plus $1,170 in HST ($9,000 × 13%). ... The PSB is required to add to its net tax an amount of $585 ([$1,500 × 13%] × 3), which is accounted for by the PSB on line 104 (or on line 105 if filing electronically) of its October GST/HST return. ...

Excise and GST/HST News- No. 114, August 2023-- summary under Subsection 280(1) Summary Under Tax Topics- Excise Tax Act- Section 280- Subsection 280(1) P-194R2 cancelled in light of Villa Ste-Rose GST/HST Policy Statement P-194R2 Application of Penalties and Interest when a Return and/or Rebate Application, and/or Another Return, is Received After the Due Date was cancelled on May 10, 2023 …. [D]ue to decisions rendered … [in] Villa Ste-Rose … the policy is now obsolete. ...

T2059 Election on Disposition of Property by a Taxpayer to a Canadian Partnership-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) Filing instructions (different where co-ownership) Mail one copy of this election and related schedules (as specified), completed by the transferor as follows: – to the tax centre of the transferor – on or before the earliest date on which any party to the election has to file an income tax return for the tax year in which the transaction occurred (due date). This due date must consider any election under subsection 25(1) or 99(2) – separately from any other return • When many transferors elect to transfer the same property (co-ownership) or many members of the same partnership elect to transfer their partnership interests, the elections will be processed together and should be filed: – to the tax centre of the transferee – on or before the due date – by a designated transferor to file all of the completed forms for each transferor, together with a list of all of the electing transferors. This list should contain the name, address and social insurance, trust account or business number of each transferor and of each member of the transferee – separately from any other return ...