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14 October 2016 Interpretation 170549-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) agent could not claim ITCs ACo and BCo, which were co-tenants of a property in construction held through a Nominee, signed an agency agreement in which Nominee was designated as the agent of ACo and BCo and which provided that the Nominee was the authorized agent and representative of ACo and BCo including for the claiming of input tax credits – and the Nominee made such claims prior to the end of the period of administrative tolerance expressed in GST/HST Notice 284. In rejecting this approach, CRA stated: [I]t is the principal who is entitled to claim any input tax credits on the supplies acquired by the agent on behalf of the principal. … The statement in the agency agreement stating that the Nominee will claim ITCs on inputs purchased in its capacity as agent does not extinguish ACo and BCo’s potential right to claim the ITCs under the ETA, nor does it result in the Nominee being entitled to claim ITCs. ...

. … In these circumstances, often the predominant element of the supply made by a downstream merchant is the provision of a licence in respect of real property (that is, providing space or a location for the ABM). This is a taxable supply. … Where the predominant element of the supply consists of replenishing money, providing telephone lines, electricity or any combination thereof, the supply would also generally constitute a taxable supply. ...

. … Therefore … if all the information related to the supply is accessible and is prescribed information that enables the CRA to determine the amount of the ITC, then that information will be acceptable to the CRA as satisfying the documentary requirements under subsection 169(4). ...

. … If there is no transfer of ownership of a particular property, we do not consider a supplier to have sold, and a recipient to have purchased, the property. … Accordingly, property leased from a lessor is generally not considered to have been acquired for income tax purposes and, as such, is not treated as capital property for purposes of the ITA or, by extension, the ETA. ...

18 May 2018 Interpretation 183321-- summary under Subparagraph 174(a)(iv) Summary Under Tax Topics- Excise Tax Act- Section 174- Paragraph 174(a)- Subparagraph 174(a)(iv) allowance recognized even though subsequently donated back to charity Some of the volunteers at a registered charity are reimbursed for their expenses, or receive an allowance – but then donate those payments to the charity for a donation receipt. ... Accordingly, the expenses claimed by the charity for public service body (PSB) rebate purposes include the expenses recognized under ETA s. 175 or 174 as a result of its having paid the reimbursements or allowances – notwithstanding that those expenses in effect are donated back to it. ...

. … Appeal of adverse designation decision 2.6. An organization that does not meet the criteria for QCJO designation will also receive a letter from the CRA confirming the decision. … If the original decision does not change, the organization may apply for judicial review of the decision to the Federal Court of Canada. ...

Its reasoning: Based on … the operator … not hav[ing] an interest in the real property on which the MURC is situated, the operator does not meet the conditions set out in paragraph (a) of the definition of “builder.” ...

CRA stated: One of the conditions for making a section 167 election is that if the supplier is a registrant, the recipient must be a registrant … [which] is a question of fact … There is no provision deeming a predecessor (in this case, Newco) to acquire the characteristics of its successor Amalco. ...

4 December 2023 Canadian Tax Foundation Event Announcement-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income policy changes announced on 28 November 2023 are effective for taxation years commencing after that date On December 4, 2023, the Canadian Tax Foundation posted the following message on CRA's behalf regarding CRA’s oral presentation (with slides) made on November 28, 2023 entitled, “ S. 55(2) and Safe Income- Where Are We Now? ”: Pursuant to our presentation on Safe Income at the 2023 Annual Conference on November 28, 2023, all announcements that constitute a change in position will apply prospectively to calculations of safe income for taxation years beginning after November 28, 2023. ...

CRA News Release, “Bare trusts are exempt from trust reporting requirements for 2023,” 28 March 2024-- summary under Subsection 150(1.2) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2) Cancellation of bare trust reporting obligation for calendar 2023 In recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians, the Canada Revenue Agency (CRA) will not require bare trusts to file a … T3 return … including Schedule 15 (Beneficial Ownership Information of a Trust), for the 2023 tax year, unless the CRA makes a direct request for these filings. ...