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CRA responded: As described in … 4-5-3 … an “emergency” is an unforeseen event or combination of events that calls for immediate action. ... Whether a particular repair service referred to as a “bad order” would qualify as an emergency repair service for purposes of section 6.1 of Part V of Schedule VI … would depend on the facts of each situation. ...

Will CRA apply the FCA’s decision to all similar situations – and can a single supply be broken down into “inherently distinct” parts for other purposes? ... We note that the end result of the FCA decision is generally consistent with the CRA’s position … B-103 … regarding the application of the place of supply rules in section 142 to services in relation to real property, pursuant to which only the proportion of the service that relates to the real property that is situated in Canada is considered to be made in Canada and subject to GST/HST. ...

CRA responded: [A]s noted in … IT-529 … “[I]n order for a health care spending account to qualify as a plan of insurance, there must be a reasonable element of risk. ... In a situation where a corporation provides a self-insured HCSA for its only employee who is also its sole shareholder (sole employee-shareholder), it is likely that the sole employee-shareholder would be reimbursed for the full amount allocated to him or her annually. … ...

. … A corporation with a marginal financial contribution to a joint venture in exchange for a co-ownership interest and proportionate share of profit (or losses) as well as other necessary attributes may be a "participant” as defined in paragraph (a) of … P-106 …. ...

Limitation Period on Discretion for Relief of Penalties and Interest ¶ 13. ... The taxpayer must comply with such requests within the stipulated timeframes…. iii) Penalty ¶ 38. A disclosure must involve the application, or potential application of a penalty. … In the event a penalty does not apply, the taxpayer cannot seek relief through the VDP. … iv) One Year Past Due ¶ 39. ...

However, there is no time limitation for assessing the following penalties: • the 6% penalty assessed under section 280; • the failure-to-file penalty under section 280.1; • the penalty for false statements and omissions under section 285; and • the third party penalty under section 285.1. ...

. … [R]egistered charities that wanted to work through a non-qualified donee [formerly] could only do this in one way. Charities had to show that the activities were their own, demonstrated by maintaining ongoing direction and control over the use of their resources. 2. … With [the enactment of the qualifying disbursement rules], charities can support the activities of non-qualified donees (grantees), provided charities can show that they meet accountability requirements set out below. … 12. … [A] charity continues to be able to carry on activities using an “intermediary”, provided the charity exercises “direction and control”. … 14. ... With pooled grants, the CRA’s requirements focus on the charity implementing the following accountability tools: … ...

CRA responded: Our position on the interpretation of section 186 … has not changed. …[W] e would, for example, apply … the Miedzi case … where a particular situation has the same facts ….. ...

The CRA has defined primarily to mean more than 50%. 7. … The following factors … may be used to determine whether a premises is an establishment of a supplier: who has authority over making operational decisions in the establishment who has control of day-to-day operations of the establishment who has presence in the establishment the types of activities and routine carried on in the establishment … Example 3: attendance of such an individual at a day program of ABC … In addition to rendering care and supervision at its establishment Monday to Friday from 9 am to 3 pm, ABC includes day trips twice weekly to places such as museums, bowling alleys, and movie theatres. Since the service of providing care and supervision is rendered principally at ABC’s establishment, the supply made by ABC is an exempt supply under section 3 …. ... Throughout the day, healthy snacks are offered to the individuals at no extra cost. … The provision of care and supervision is the dominant element of the supply … [and] the transaction … constitutes a single supply of a service. ...

CRA responded: The following responses assume that where an arrangement is described as a joint venture in the question it has the characteristics of a joint venture as delineated in … P-103 …. ... With respect to the facts in this question: • The transfer by A to B of 25% interest would not meet the criteria for a section 167 election. • Assuming that B is transferring to C its entire interest when it transfers its 85% share, and that the supply is not from a registrant to a non-registrant, the supply would qualify for a section 167 election. • The transfer by A to C of its remaining entire 15% interest may qualify depending on the facts of the situation. ...