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. … In general, any eligible rebate under Division VI will be for all or part of the tax paid or payable in respect of a particular transaction or deemed supply…. CRA referred to the statement in Fanshawe College, 2006 TCC 652, at para. 58 (foll’d Ottawa Hospital, 2010 TCC 53) that “The word "matter" in section 262…relates to a transaction” – but then stated: There are instances where a particular transaction can give rise to more than one rebate. ... If the time limit for objecting has passed, the person can write in and ask for a reassessment of the rebate claim for the particular claim period. … As another example, a selected PSB filed a rebate application claiming a PSB rebate of 50% of the non-creditable tax charged in respect of a particular transaction for a particular claim period. ...

A “foreign corporation” includes not only corporations incorporated outside Canada but also Canadian-incorporated corporations which are controlled directly or indirectly by a foreign entity as per ITA s. 256 – and also Canadian-incorporated corporations which are not listed on a Canadian stock exchange and which are “controlled…in part” by a foreign national or other foreign corporation. ... There also are narrowly-cast exemptions re personal use by foreign nationals within the Ontario Immigrant Nominee Program or refugees – as well as limited rebate provisions re foreign nationals who subsequently (within four years) become Canadian citizens or permanent residents, who are full-time Ontario students for the following two years or who legally work full-time in Ontario throughout the following year. ... There are various uncertainties in the absence of draft legislation or administrative guidance including: Would sequencing partnership purchases minimize the tax – for example if a partnership with 100% Canadian partners purchases on Day 1 and on Day 2, a non-resident subscribes for a 1% partnership interest, would this limit the 15% tax to 1% of the property value? ...

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Interpretation of gross revenue, and examples 2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s. 248(1)] also applies for purposes of the Regulations. 2.21 For purposes of Part IV of the Regulations, gross revenue includes all amounts received or receivable by a taxpayer, other than on account of capital. ... Gross revenue of a corporation would typically include amounts received by the corporation from its principal business operations as well as other amounts received or receivable that a corporation considers incidental to its business operations. … 2.22 Examples of amounts that would normally be included in determining gross revenue of a corporation for purposes of Part IV of the Regulations are: Sales of goods or merchandise by a corporation. ... Proceeds received on the disposition of property that was included in the inventory of a business upon the disposition of or ceasing to carry on the business. … [A]n amount received or receivable as proceeds of disposition of a capital property and any consequential income inclusions under sections 13 or 38 on the disposition is excluded from gross revenue. ...

. … The exemption under section 9 of Part III of Schedule V does not apply to services of tutoring or instructing individuals in courses offered at the post-secondary level (for example, college-level courses). ... Driving School A has been [so] approved …. Driving School A provides driving instruction to individuals enrolled in a secondary school in the particular province and to individuals who are not enrolled in a secondary school in the particular province. ... The service of driving instruction provided to the individuals who are not enrolled in a secondary school in the particular province and who are not eligible to receive 2 credits towards a certificate of graduation is not exempt …. ...

. … Secondary bond purchases generate good interest 35. However, if a person purchases bonds on the secondary market (that is, from a person other than the issuer of the bonds or an agent thereof), the person is not considered to have lent money to the bond issuer. Cash generates bad interest Example 3 … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

. … The courts have found that, in interpreting the meaning of "pertains to" or "incident to" in context, there has to be a financial relationship of dependence of some substance between the property in question and the active business before the property is considered to be incident to or to pertain to the active business carried on by the corporation. ... If a corporation is incorporated to earn income by doing business, there is a general presumption that profits arising from its activities are derived from a business …. ...

. … For example, A and B execute an agreement in which A agrees to sell and B agrees to buy an interest in land. … The consideration is the assumption of an existing mortgage and payment of cash. ...

26 February 2015 CBA Roundtable, Q. 13-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) JV + management agreements can qualify as “an agreement”/“co-ownership agreement” can be a JV agreement Q.1 Can a written agreement, that describes the relationship between the participants as co-ownership of property (rather than as a joint venture), qualify as an agreement evidenced in writing for purposes of s. 273(1)? ... This would require at least two participants being participants under paragraph (a) of the definition of “participant” in… P-106 …. ...

. … A written request to have the election or revocation of an election filed late must be submitted to the Assistant Director of Audit of the tax services office of the first specified member making or revoking the election as identified on the Form RC4616. … The written request must provide a clear explanation as to why the specified members have filed the election or revocation late…. ...

After finding that IMEs performed after March 21, 2013 generally are taxable supplies, CRA noted: … In the case where a patient is examined in Canada and the report is prepared outside Canada, the supply of the service is deemed to be made in Canada pursuant to paragraph 142(1)(g), as the services are performed in part in Canada. ... An IME … consists of an examination of the patient, reviewing medical documentation, dictation, editing and printing a report on the findings. ...