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CRA responded: Since … Corporations A and B were the persons that established or carried on the business, AmalCo cannot be considered to have done so, since it is deemed to be a separate person for GST/HST purposes. … [By virtue of s. 271(b)] where an amalgamation occurs for GST/HST purposes, the transfer of property or services to AmalCo by Corporations A and B under the amalgamation agreement does not constitute an acquisition made by AmalCo from those corporations, since AmalCo is deemed to be the same person and a continuation of those corporations in respect of that property or those services. ... Thus … AmalCo cannot be considered to have “acquired” a business established or carried on by another person in accordance with section 167 nor be considered the recipient of a supply of a business. ...

28 February 2019 CBA Roundtable, Q.26-- summary under Subsection 221(2) Summary Under Tax Topics- Excise Tax Act- Section 221- Subsection 221(2) vendor can rely on inquiries with purchaser A supplier relied on the GST/HST Registry – which showed that the recipient of a sale of real estate (a charity) had a business number ending in RT0001 – in not charging HST on the sale. ... CRA responded: (a) The Business Number and Authorization Division, Business Returns Directorate, Assessment, Benefit, and Service Branch, recently confirmed that they have resolved the issue of false positives that occurred in some instances …. ...

. … A corporation with a marginal financial contribution to a joint venture in exchange for a co-ownership interest and proportionate share of profit (or losses) as well as other necessary attributes may be a "participant” as defined in paragraph (a) of … P-106 …. ...

The server plays a more limited role in cryptocurrency mining – solving algorithms. ... To be a permanent establishment the non-resident person must make supplies through that fixed place of business – meaning the activities carried out by the non-resident server must, on their own, be an essential and significant part of the business activity of the non-resident person as a whole. … The CRA currently has a couple of ruling requests that involve cryptocurrency mining, and is currently reviewing whether a non-resident miner with servers in Canada would be considered to have a permanent establishment in Canada by virtue of the mining activities that are carried on through those servers. ...

., less than 90%) in the registrant's commercial activities, CRA stated: Generally, subsection 202(4) … provides for an ITC (determined by the formula 'A x B') equal to the tax fraction (7/107) of the CCA in respect of the passenger vehicle or aircraft that was deducted under the Income Tax Act in computing the income of the registrant from those commercial activities for that taxation year of the registrant. … [A]lthough [s. 202(4)] does not require the registrant to segregate the class 10 vehicle from all other property in that class… it does, however, call for a separate calculation to be made by the registrant (formula 'A x B' discussed above) to determine the correct amount of ITC available on the passenger vehicle. It is therefore our opinion that a separate tracking system may be required …. ...

He noted that the August 9 GAAR consultation paper stated at its outset that Finance thinks the GAAR is working reasonably well – but, even so, it could do with a tune-up after more than 30 years of practice, experience, tax administration and case law. ... Although the paper sought to cover the possible proposals in a balanced manner, even being transparent where a possibility was perhaps not workable or necessary, some of the proposals still prompted strong reactions – all of which is an expected and useful part of the consultation process. ... Although the judicially developed analytical framework is reasonably sound, there are some cases that may benefit from a further statutory “nudge” with regard to economic substance – and the case was made in the paper for this benefiting the efficiency of the system overall. ...

For each billing period, the supplier is deemed to have made, and the recipient is deemed to have received, a separate supply of the service on the earliest of: • the first day of the billing period; • the day the payment for that billing period becomes due; and • the day the payment attributable to the billing period is made. 75. ...

. … Number Title T2224 Transitional Rules Election T2225 Group Ratio Rules Election under subsection 18.21(2), and Fair Value Adjustments Election under subsection 18.21(4) T2226 Election to Transfer Cumulative Unused Excess Capacity under Subsection 18.2(4) T2227 Excluded Interest Election Under Subsection 18.2(1) T2228 Specified Pre-regime Loss Election under subsection 18.2(1) T2229 Election to forgo a foreign accrual property loss under clause 95(2)(f.11)(ii)(E) … How to file the election before the forms are available If you need to file an election before the forms are available, you may send a letter containing the information required under the relevant election provision in the Income Tax Act with the signatures of all taxpayers or partnerships who are party to the election. … You will need to submit a separate letter for each election. ...

. … The Income Tax Act (ITA), Employment Insurance Act (EIA), and Canada Pension Plan (CPP) which govern the withholding, remittance, and collection of payroll/source deduction amounts, contain no statutory analogue to the ETA provisions which would allow for the postponement of collection of amounts owing which are under appeal or objection. … Where the taxpayer has made … arrangements [with CRA collections], CRA collections does have the administrative authority to withdraw any collection actions such as garnishment, so long as the payment arrangement remains in good standing. ...

CRA indicated that “[o]nce GST/HST returns are filed, the registrant will receive a notice of assessment if either …a refund or rebate is owed … [or] the amount owing is more than the payment made by the registrant” – but not if the amount owing on the return as filed equals the payment made on filing. However, if the returns are filed pursuant to a voluntary disclosure request, “a NOA will be issued once the voluntary disclosure has been accepted and finalized” – even though, to be accepted, the voluntary disclosure application must “include payment of the estimated tax owing.” ...