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8 March 2007 Canadian Bar Association Commodity Tax Section Roundtable, Q. 30-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) Q.30 – Joint Venture …. ...

B-107 "Investment Plans (Including Segregated Funds of an Insurer) and the HST" April 2013-- summary under Subsection 34(1) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 34- Subsection 34(1) 19.1.1 Provincial attribution percentage – selected province.. ...

Cathy Hawara, Director General, Charities Directorate, "The CRA Charities Directorate's Approach to Compliance", 2014 Conference Report, Canadian Tax Foundation, 37:1-10-- summary under Subsection 188.1(9) Summary Under Tax Topics- Income Tax Act- Section 188.1- Subsection 188.1(9) 1-10 Penalty for false information – fraudulent receipting also often results in revocation or criminal charges (pp. 37:6-7) A person who makes or participates in the making of a false statement on a receipt is liable to a penalty equal to 125 percent of the eligible amount. ...

In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ... Interest will be adjusted consequentially …. These transfer pricing principles will also apply to all taxation years after 2010, including the 2011 to 2015 taxation years which are currently under audit and on a go forward basis [as to transfer pricing matters under current law]. ...

Note: on the RC4649, the reporting entity is either: • the UPE • an SPE – a Canadian CE that has been designated as a surrogate parent of a foreign UPE. Note: A Canadian CE cannot be designated as an SPE of a Canadian UPE • a CE, in cases of a local filing requirement Filing obligations of Canadian CE that is SPE Obligations of a surrogate parent entity in Canada A CE resident in Canada that is appointed as an SPE of a foreign UPE is subject to filing requirements as if that entity were a UPE in Canada. In particular, subsection 233.8(1) of the Act defines an SPE as a CE of an MNE group that has been appointed by the MNE group — in substitution for the UPE — to file the CbC report on behalf of the MNE group, if one or more of the conditions in subparagraph 233.8(3)(b)(ii) applies (i.e., the conditions for the secondary reporting mechanism to apply). ...

The remaining 40% of the services are not improvements to capital property, and are to be expensed for income tax purposes. … Therefore, the GST deemed payable for the improvements to the apartment building is $300 (i.e., $500 × 60%). The ITC available on the improvement is calculated in accordance with subsection 169(1) and paragraph (b) of element B of the formula in that subsection, and is equal to $60 (i.e., $300 × 20%). ... However, if the repair services were partly (e.g., 20%) for consumption or use in commercial activities and partly (e.g., 80%) for consumption or use in non-commercial activities, an ITC of $40 (i.e., $200 × 20%) could be claimed in accordance with subsection 169(1) and paragraph (c) of element B of the formula in that subsection. ...

. … [T]he word “ownership” generally refers to the legal ownership (that is, “titled” ownership in the case of the underlying real property), rather than equitable ownership of the property. … Based on the assumptions that: (a) the Builder has actual possession of the Developed Lots or the Developed Land pursuant to the Sale Agreement, and (b) the Sale Agreement provides that beneficial ownership of the House or Unit situated on the Developed Lot or Developed Land (as the case may be) is transferred to the Builder at Initial Closing, one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership to the Builder on demand, or to any third party at the Builder’s request (for example, to the Home Buyer …). So, with respect to this scenario, provided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. Therefore … provided that all of the other conditions … are met, the Builder may pay or credit the Rebate to the Home Buyer. ...

Before concluding that the supply of the service would be in New Brunswick, CRA stated: A service and real property would generally be regarded as being in relation to each other pursuant to the above guidelines if the purpose of the service is to: • physically count the property; • appraise or value the property; • physically protect or secure the property; or • enhance the value of the property. ...

Excise and GST/HST News- No. 114, August 2023-- summary under Subsection 280(1) Summary Under Tax Topics- Excise Tax Act- Section 280- Subsection 280(1) P-194R2 cancelled in light of Villa Ste-Rose GST/HST Policy Statement P-194R2 Application of Penalties and Interest when a Return and/or Rebate Application, and/or Another Return, is Received After the Due Date was cancelled on May 10, 2023 …. [D]ue to decisions rendered … [in] Villa Ste-Rose … the policy is now obsolete. ...

CRA responded: Our position on the interpretation of section 186 … has not changed. …[W] e would, for example, apply … the Miedzi case … where a particular situation has the same facts ….. ...