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In situations where Holdco wholly owns a distributing corporation (Opco) and assets of Opco are spun-out to a transferee corporation (Newco) that is also owned by Holdco, the general formula for the split of the direct safe income (DSI) between Holdco and Newco is as follows: DSI on the shares of Newco: DSI of Opco prior to reorganization X net cost amount of the assets transferred to Newco / total net cost amount of the assets of Opco prior to the reorganization DSI on the shares of Opco after the reorganization: DSI of Opco prior to the reorganization X net cost amount of the assets retained by Opco / total net cost amount of the assets of Opco prior to the reorganization In a one-wing split-up butterfly wherein a portion of the assets of a corporation (DC) owned by Holdco1 and Holdco2 is spun-off to Holdco2, there could be a resulting misalignment of basis (including safe income that could be capitalized), so that Holdco1 could simply sell the shares of DC without any negative implications and Holdco2 could sell the assets it received with an increased ACB. ... For instance, CRA indicated that where there was a spin-off of ½ of the assets of Opco to Newco, entailing a transfer of ½ of the shares of Holdco’s shares of Opco to Newco, it might be necessary for less than ½ of the ACB of the shares of Holdco in Opco to be transferred to Newco. ...

Consequently … A Co has a contingent right to be paid money from Drug Co. … A Co will make a supply of these same contingent rights to Finance Co. ...

In its explanation, CRA briefly described satisfaction of the “qualifying funding" requirement in s. 259(2.1) as well as the facility accreditation requirement in s. 259(2.1)(c) (here, by the MOHLTC), and focused on the “facility supply” requirement, stating: Elim Housing … made the determination that Elim was entitled to claim the 83% PSB rebate as a facility operator operating a qualifying facility based on the presence of the following elements which indicated Elim to be making facility supplies: all of the residents had conditions that required “complex care” …; the residents were extremely dependent on care either by reason of mental or physical impairment …; residents were under the care of a physician, who was either associated with the facility or had a pre-existing relationship with the resident; a tailored care plan was created for each resident, documented and implemented: … physicians visited residents frequently (e.g., roughly on a bi-weekly basis); physicians were at, or on-call to attend, the facility at all times; physicians provided substantial medical care (e.g., addressed medical concerns, participated in medication reviews, attended interdisciplinary meetings); registered nurses were at the facility at all times, and nurses were in regular communication with physicians for prescription or advice; the facility received funding for 2.8 hours of care per resident per day (the calculation was based on scheduled staffing hours); the care provided was of a different type than ordinary assistance with activities of daily living that a more robust individual might require. ...

II, s. 9, CRA turned to the supplies made by the Corporation and stated: The […] Agreement indicates that the [Service Providers] agree to provide the services as described in […] through their profession…. ...

The qualifying revenue of an eligible employer … would include the revenue arising from the sales of new products. … [Q.6-2.3] Forgivable portion of a Canada Emergency Business Account (“CEBA”) loan not included in qualifying revenue The forgivable portion of a CEBA loan meets all the characteristics of an extraordinary item … [and] is not included in qualifying revenue. ... Likewise, qualifying revenue calculations cannot be adjusted for a recent expansion of an eligible employer's normal operations …. ... … Where an eligible employer’s normal accounting practice is to convert the inflow of cash, receivables and other consideration to Canadian currency from a foreign currency, then the eligible employer would be expected to use the Canadian currency equivalent of the amounts in the computation of qualifying revenue. ...

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Subsection 261.1(1) Summary Under Tax Topics- Excise Tax Act- Section 261.1- Subsection 261.1(1) Application to public service body Example 22 – Goods acquired in a participating province and removed to another participating province In a claim period, a non-registrant PSB purchases goods in New Brunswick for $19,000, on which it pays $2,850 in HST ($19,000 × 15%). ... The federal part of the HST paid in respect of the purchase is $950 ($2,850 × 5/15). ... The provincial part of the HST paid in respect of the purchase is $1,900 ($2,850 × 10/15). ...

Example 24 – Services acquired in participating province for partial use in another participating province In a claim period, a non-registrant PSB resident in Nova Scotia purchases advertising services in Nova Scotia for $5,000, on which it pays $750 in HST ($5,000 × 15%). ... The federal part of the HST paid in respect of the advertising services is $250 ($750 × 5/15). ... The provincial part of the HST paid in respect of the advertising services is $500 ($750 × 10/15). ...

Excise and GST/HST News- No. 97 17 November 2015-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 7 Acupuncture services – need for patient relationship Only services rendered by a practitioner of acupuncture to an individual within a practitioner-patient relationship are exempt from the GST/HST under the exemption for acupuncturists. This means that the practitioner must be a direct care provider of the patient and a relationship involving personal interaction between the practitioner and the patient must have been established for the exemption to apply. … Overlapping exemptions (e.g., dentist/acupuncturist) …[I]n some provinces a dentist may perform acupuncture services within the scope of practice for a dentist. ...

Example 2 – Goods imported into Canada In a claim period, a registrant PSB resident in New Brunswick purchases commercial goods in the United States and imports them into New Brunswick for use by the PSB exclusively (90% or more) in its commercial activities in that province. The goods are valued at $15,000 (including duties), on which the PSB pays $750 in GST ($15,000 × 5%) to the CBSA at the time of importation of the goods. ...

Example 14 – Seized property used by creditor A registrant PSB resident in Saskatchewan is not a charity to which subsection 225.1(2) (net tax calculation for charities) applies. ... The PSB is deemed to have collected GST of $1,250 ($25,000 × 5%) on the fair market value of the office equipment. ...