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. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ...

Is it possible to report the GST/HST in the registrant’s GST/HST Return GST34 for the reporting period that includes the closing date – just like other taxpayers who use the property more than primarily in commercial activities- and offset the self-assessed GST by claiming appropriate ITCs on line 108 or PSB rebates on line 111 of the same Return? ... To apply the offset, the two forms must be filed together. … Therefore, if a registrant public service body’s PSB rebate claim and GST60 return are due to be filed at the same time, the registrant may offset any tax remittable when the forms are filed together. ...

(a) because they were “purposely constructed or converted to be a separate and self-contained set of private living quarters” – even though their use may be diverted to provide transient accommodation. ... Not a residential property prior to substantial completion (para. 1.30, 1.31) For purposes of both (a) and (b) of the definition, CRA considers that a property in construction does not become a residential property until “construction of the property is substantially completed (generally 90% or more) so that an individual could reasonably inhabit the property” – so that there is no reporting obligation for the property if on December 31 it has not yet become a residential property. ...

The test still has a gatekeeping function – avoidance still must be one of the “main” purposes – before getting to the “misuse or abuse” analysis, but this represents a more modern approach to avoidance transaction rules, and gets around some of that analytical uncertainty in situations where there are multiple purposes, leading to an artificial exercise in picking the “winner” from among those purposes. ...

. … A reassessment may be made. This means that the objection is allowed in whole or in part, and the amount assessed is adjusted. ... The assessment may be confirmed. … An upward reassessment may be made. ...

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. ...

. … In general, any eligible rebate under Division VI will be for all or part of the tax paid or payable in respect of a particular transaction or deemed supply…. CRA referred to the statement in Fanshawe College, 2006 TCC 652, at para. 58 (foll’d Ottawa Hospital, 2010 TCC 53) that “The word "matter" in section 262…relates to a transaction” – but then stated: There are instances where a particular transaction can give rise to more than one rebate. ... If the time limit for objecting has passed, the person can write in and ask for a reassessment of the rebate claim for the particular claim period. … As another example, a selected PSB filed a rebate application claiming a PSB rebate of 50% of the non-creditable tax charged in respect of a particular transaction for a particular claim period. ...

A “foreign corporation” includes not only corporations incorporated outside Canada but also Canadian-incorporated corporations which are controlled directly or indirectly by a foreign entity as per ITA s. 256 – and also Canadian-incorporated corporations which are not listed on a Canadian stock exchange and which are “controlled…in part” by a foreign national or other foreign corporation. ... There also are narrowly-cast exemptions re personal use by foreign nationals within the Ontario Immigrant Nominee Program or refugees – as well as limited rebate provisions re foreign nationals who subsequently (within four years) become Canadian citizens or permanent residents, who are full-time Ontario students for the following two years or who legally work full-time in Ontario throughout the following year. ... There are various uncertainties in the absence of draft legislation or administrative guidance including: Would sequencing partnership purchases minimize the tax – for example if a partnership with 100% Canadian partners purchases on Day 1 and on Day 2, a non-resident subscribes for a 1% partnership interest, would this limit the 15% tax to 1% of the property value? ...

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Interpretation of gross revenue, and examples 2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s. 248(1)] also applies for purposes of the Regulations. 2.21 For purposes of Part IV of the Regulations, gross revenue includes all amounts received or receivable by a taxpayer, other than on account of capital. ... Gross revenue of a corporation would typically include amounts received by the corporation from its principal business operations as well as other amounts received or receivable that a corporation considers incidental to its business operations. … 2.22 Examples of amounts that would normally be included in determining gross revenue of a corporation for purposes of Part IV of the Regulations are: Sales of goods or merchandise by a corporation. ... Proceeds received on the disposition of property that was included in the inventory of a business upon the disposition of or ceasing to carry on the business. … [A]n amount received or receivable as proceeds of disposition of a capital property and any consequential income inclusions under sections 13 or 38 on the disposition is excluded from gross revenue. ...

. … The exemption under section 9 of Part III of Schedule V does not apply to services of tutoring or instructing individuals in courses offered at the post-secondary level (for example, college-level courses). ... Driving School A has been [so] approved …. Driving School A provides driving instruction to individuals enrolled in a secondary school in the particular province and to individuals who are not enrolled in a secondary school in the particular province. ... The service of driving instruction provided to the individuals who are not enrolled in a secondary school in the particular province and who are not eligible to receive 2 credits towards a certificate of graduation is not exempt …. ...