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CRA indicated that it can accept such an arrangement as being valid notwithstanding that all of the source deductions are handled on the payroll account of only one of the dentists, who does the remittances, and source deduction and T4 reporting, as agent for the other dentists as well as on her own behalf – and also pays the staff remuneration as agent and is reimbursed on a pro rata basis by the other dentists. ...

CRA considers its usual approach to be “administrative relief” because, as a technical matter, “the tax payable [under s. 228(4)] is not part of the registrant’s net tax calculation” – so that in CRA’s view it is in its discretion as to whether, in addition to assessing the purchaser’s s. 228(4) tax, it also assesses the purchaser’s negative net tax resulting from recognizing the unclaimed ITC. ...

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. … Paragraph (d) of the definition of “financial instrument” in subsection 123(1) includes an interest in a partnership or any right in respect of such an interest. ...

19 April 2017 Interpretation 183783-- summary under Subsection 296(2.1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(2.1) a registrant cannot use ETA s. 296(2.1) to avoid having to file a GST/HST rebate claim A non-registered corporation which had failed to self-assess itself, subsequently sent in a late return accompanied by a note to the effect that that unclaimed GST/HST rebates existed – but without filing any rebate claim. ...

. … Where pursuant to the state, provincial or federal laws under which the entities are incorporated, the predecessors are continued as one corporation with the new successor being a continuation of the predecessors (otherwise than as a result of a purchase or distribution of property described above), it appears that section 271 would apply. ...

. … Note that the legislation uses the word “may”. As such, it is at the discretion of the Joint Venture (the particular person) whether to refund the GST on the reduction in consideration. ...

However, in the case of the foreign demergers rule in s. 15(1.4)(e) – for which Finance had proposals for improving its operation- there were some issues that were identified with it. ...

28 February 2019 CBA Roundtable, Q.16-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) CRA accepts ONEnergy, including that “either” s. 141.1(3) or 141.01(2) can be satisfied ONEnergy … held that s. 141.1(3), which provides for an input tax credit where the property or service is acquired in connection with the acquisition, establishment, disposition or termination of a commercial activity, is more specific than s. 141.01(2), so that a person will not lose the entitlement to claim an ITC solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...

. … Municipalities in participating provinces may be entitled to a PSB rebate of 100% of the federal part of the HST but only entitled to a lesser percentage of the provincial part of the HST. ...