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Summary of 6 October 2017 APFF Roundtable, Q.6 under Treaties – Art. 5. ...

Summary of 6 October 2017 APFF Roundtable, Q.7 under s. 54 – capital property. ...

. … [T]he CRA will not require Form T2091 to be completed…. Neal Armstrong. ...

Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement relating to the division of property with the annuitant’s common-law partner or former common-law partner” – and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure has been previously signed.” ...

. … CRA went on to acknowledge the six-year normal reassessment period under s. 152(4)(b.2), and referenced the exception thereto for neglect etc. ...

Summaries of 6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.13 under s. 18(5) – specified right and s. 15(2.16). ...

CRA indicated that the non-resident would not be considered to be carrying on business in Canada for GST/HST purposes given that “the only relevant factor present in Canada … is the place of delivery, which is insufficient to conclude that the non-resident is carrying on business in Canada.” ...

Summary of 9 May 2016 Internal T.I. 2016-0638461I7 under s. 9 – computation of profit. ...

Summary of 23 March 2017 CBA Commodity Taxes Roundtable, Q.19 under Input Tax Credit Information (GST/HST) Regulations- s. 2 – supporting documentation. ...

Where A, who agreed to purchase a new home from the builder, assigns her purchase agreement before closing to B for consideration representing the increased value of the underlying house, the new housing GST rebate to B will be computed on the basis only of the original purchase price – unless A also constituted a builder (e.g., A had entered into the purchase contract for the primary purpose of reselling the house), in which case, the assignment fee would be taxable, and the computation of the rebate would also take into account the amount of the assignment fee. ...