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. … Further, the prohibition on both "direct and indirect" partisan political activities is highly subjective (particularly "indirect"), and has been the subject of much confusion in the charitable sector…. ... Proposed amendment allowing charities to fully engage in non-partisan public policy dialogue and development that is subordinate to and furthers their charitable purposes (pp. 17-18) Recommendation 3 …The Panel recommends that amendments: retain the current legal requirement that charities must be constituted and operated exclusively for charitable purposes, and that political purposes are not charitable purposes; fully support the engagement of charities in non-partisan public policy dialogue and development in furtherance of charitable purposes, retiring the term "political activities" … and clearly articulating the meaning of "public policy dialogue and development" to include: providing information, research, opinions, advocacy, mobilizing others, representation, providing forums and convening discussions; and retain the prohibition on charities’ engaging in "partisan political activities", with the inclusion of "elected officials" (i.e. charities may not directly support "a political party, elected official or candidate for public office"), and the removal of the prohibition on "indirect" support, given its subjectivity. … The rationale for this approach is more fully described under Recommendation 1 in the context of interim changes recommended to the policy guidance. ...

CRA responded: Pursuant to … Polygon, Builder’s supplies are characterized as taxable supplies that are outside the scope of section 191 …. …[B]ecause Builder does not make (or hold the lots for the purposes of making) exempt supplies included in section 6 or 7 of Part I of Schedule V …, DeveloperCo’s subleases of the lots to Builder are exempt under subparagraph 7(a)(ii) of Part I of Schedule V as opposed to being exempt under section 6.1 of Part I of Schedule V. ...

An individual’s continuous occupancy of the dwelling unit for a period is not necessarily interrupted by the individual’s physical absence from the dwelling unit at a time in the period if both of the following apply: the individual still has the right to occupy the dwelling unit throughout their physical absence the right to occupy the dwelling unit is not given to another individual for any period during the physical absence Tests varying on whether an individual owner and whether a written lease No day can be counted more than once As explained above, if you are an affected owner that: is an individual, you can determine if there is a qualifying occupancy period for your ownership of a residential property as explained under one of the following headings: Type 1 qualifying occupants – individuals having agreements evidenced in writing Type 2 qualifying occupants – individual owners and their family is not an individual (such as a corporation), you can determine if there is a qualifying occupancy period for your ownership of a residential property only under the heading Type 1 qualifying occupants – individuals having agreements evidenced in writing In either case, your ownership of the residential property does not qualify for the exemption for qualifying occupancy unless at least 180 days in a calendar year are included in one or more qualifying occupancy periods for your ownership of the residential property. ...

. … Causal allocation 46. Causal allocation directly approximates the use of a particular business input using a logical and systematic approach and an appropriate allocation base. 47. ... An input-based allocation uses a calculation based on the procurative extent of other business inputs. … 51. ... Further, other distorting factors must be excluded from the ITC calculations in a revenue‑based method …. ...

. … When the vendor does not have to charge tax A different rule applies for used goods you accept as a trade-in from a person who is not required to charge GST/HST (usually a person who is not required to register for GST/HST). ... In this case, you generally charge GST/HST on the net amount of the sale or lease, that is, the price of the goods you sell or lease minus the amount you allow for the trade-in. … [S]ee GST/HST Technical Information Bulletin B-084, Treatment of Used Goods. ...

. … If the company's responsibility is limited to providing registered or licensed nurses to the facility so that the facility may satisfy its own staffing requirements, and the nurses are subject to the control of the operator of the facility and render services under the direction of the facility in accordance with the facility's responsibility to provide care to a patient or resident of the facility, the company has made a taxable supply of personnel or human resources, and not a supply of exempt nursing services. … However, if the company is responsible for the provision of nursing services to the patients or residents of the facility and is accountable for the quality of nursing care provided, the company may have made an exempt supply of a nursing service rendered by a registered or licensed nurse to an individual, where the service is provided within a nurse-patient relationship. ...

As discussed in the Excise and GST/HST Rulings memorandum issued […] on [mm/dd/yyyy] (RITS […]), where a receiver (such as a single asset receiver) is responsible for only a part and not all of the person's businesses, properties, affairs or assets, the receiver may use a sub-account of the person's GST/HST registration account for GST/HST purposes. ...

. … … Results of the 2013-14 Audit Program Outcome Files Percentage Education letter 513 61.0 Compliance agreement 137 16.5 Clean 112 13.5 Notice of intent to revoke issued 34 4.0 Voluntary revocation 20 2.5 Other (part V audits, pre-registration audits, etc.) 13 1.5 Annulment 6 0.5 Sanctions 5 0.5 Total (excluding political activities audits) 840 100.0 Tax shelter audits (p. 37:6) [T]he CRA…will continually audit tax shelter gifting arrangements, which includes auditing all registered charities that play a role in a tax shelter gifting arrangement. ...

Effecting repatriation Repatriation can be accomplished by: offsetting inter-company accounts receivable from the non-resident – It should be remembered that this method of repatriation might have an effect on other items. For example, interest charges may have to be adjusted on a going-forward basis to reflect the revised inter-company balances; the transfer of money or its equivalent to the non-resident corporation; where a Canadian parent company cannot otherwise effect repatriation within a reasonable time, the creation of a shareholders loan account – This would be effective at the date of the transfer pricing transaction and may result in the application of subsection 15(2) of the Act; or netting upward and downward transfer pricing adjustments from different non-residents if both the taxpayer and all the non-residents involved agree in writing to have the amounts offset.... ...

. … [T]he CRA considers the "particular reporting period" to be the reporting period in which the ITC or deduction first became claimable. … P149 deals with situations where a registrant makes a request to have CRA adjust a previously filed return and does not apply to returns under audit or examination. ...