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In response to a suggestion that it was CRA policy that “if a public service body has been charging GST/HST on supplies of real property that would otherwise be exempt, and has been accounting for that tax and claiming input tax credits (ITCs) in its net tax calculations and remittances as if the s. 211 election had been filed on time, then the CRA will normally accept a late-filed section 211 election,” CRA stated: [A] decision on whether to accept a backdated effective date for a section 211 election falls within the purview of the Domestic Compliance Programs Branch … [which] will only consider the backdating of a section 211 election in exceptional circumstances. ...

CRA also indicated, in the situation where the death had occurred before the deceased could withdraw the minimum amount for the year of death, but the transfer of his RRIF to the surviving spouse was not made until the following calendar year, then there was no need for the RRIF issuer to pay the minimum amount for the year of death – but that the eligible amount received by the surviving spouse in the subsequent year would be reduced by the minimum amount for that year. ...

V, s. 7(f) applies to “a service of … soliciting orders for supplies by or to the [non-resident recipient, i.e., NR]” whereas here the solicitation was for supplies by the Canadian customer of NR.) ...

CRA also reiterated its position that s. 296(2.1) only applies where a registrant has failed to claim (rather than claimed) a rebate – so that, for example, s. 296(2.1) could apply to require CRA to grant the NRRPR where it has assessed a developer for failure to self-assess. ...

Summary of 10 May 2019 GST/HST Ruling 167225 under ETA s. 123(1) – debt security. ...

CRA also noted: … 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. ...

I, s. 7 rather than s. 6.1 or 6.11, DeveloperCo was not entitled to a rebate under s. 256.1 for the HST charged to it on the development costs borne by it – notwithstanding that the transactions generated fully-taxable revenues from the sublease purchasers. ...

Summary of Kailey McLeod and Nadia Pulla, “Misalignment of Federal and Provincial Tax Credits,” Canadian Tax Focus, Vol. 9, No. 4, November 2019, p.8 under s. 126(7) – non-business-income tax. ...

., a “right under a contract … to control the voting rights attached to the share.” ...

Summary of Finance Comfort letter entitled “Cross-Border Surplus Stripping & Graduated Rate Estates” dated 2 December 2019 under paragraph 212.1(6)(b). ...