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CRA indicated that it agreed with the conclusion reached as inter alia being consistent with the single supply doctrine and given that: The administrative arrangement, which permits dentists to claim ITCs based on a percentage of general operating expenses, is contradictory to the ITC provisions of the … ETA …. ...

. … The fact that the volunteer later donates all or a part of the payment back to the Charity does not impact the Charity's PSB rebate entitlement. ... Therefore, section 175 does not apply and the Charity cannot claim a PSB rebate …. ...

The Lessor, as agent for the Trust, remits the HST paid by the Lessees and pays to the Trust the full amount of the lease payment collected on behalf of the Trust – a portion of which is then paid by the Trust to the Lessor as deferred rent. ... The HST collected on the taxable supply made to the Lessee is accounted for by the Lessor as agent for the Trust (Concurrent Lessee) by virtue of the election under subsection 177(1) between the Trust (Concurrent Lessee) and the Lessor, and […] the MCLA. ...

. … As defined in section 3 of the Assisted Human Reproduction Act, an in vitro embryo means an embryo that exists outside the body of a human being. Treatment of the subject supplies before amendments passed [C]linics and donor banks are not liable to pay GST on the importation of in vitro embryos after March 19, 2019. … However, consistent with its standard practice, the Canada Border Services Agency is administering this measure on the basis of the proposed amendment. ...

. … CRA … has resolved a file regarding a hybrid mismatch arrangement involving the deduction of non-arm’s length interest in a series of transactions that included a forward subscription agreement (outlined in the diagram below) on the basis that paragraphs 247(2)(b) and (d) of the Income Tax Act and transfer pricing penalties applied. ...

For example, respecting element A: As an amount paid in error as or on account of tax is not tax, the amount should not be included in Element A of the SAM formula which includes all tax … that became payable under any of subsection 165(1) and sections 212, 218 and 218.01 by the financial institution during the particular reporting period or that was paid by the financial institution during the particular reporting period without having become payable. … CRA concluded: Consequently, if an SLFI has included an amount in Element A and Element F of the SAM formula in a particular reporting period and subsequently it is determined that the amount was paid in error by the SLFI as or on account of tax, as the amount is not tax payable under subsections 165(1), 165(2) or sections 212, 212.1, 218 or 218.01, the SLFI’s SAM formula calculation should be corrected to remove the amount from Element A and Element F for the reporting period in which that amount was included. ...

Private meetings are excluded …. Fast food chain could supply the school cafeteria lunches 5. ... The exemption under section 12 … applies to the supplies of such lunches, provided that the supplies are made primarily to students in a location determined to be a school cafeteria. ...

Canada Revenue Agency increases flat rate amount for meal claims, and reasonable amount for meal benefits and allowances 3 September 2020 CRA Press Release-- summary under Subparagraph 6(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii) Increase in presumptively reasonable overtime or travel meal allowance from $17 to $23 CRA … has increased the amount that employers can use to determine whether an overtime meal or allowance, or the meal portion of a travel allowance is taxable, from $17 to $23. ... These increases are effective immediately and retroactive to January 1, 2020. … CRA policy re exclusion of reasonable overtime or travel meal allowance The CRA’s policies on taxable benefits and allowances allows an employer to exclude the value of an overtime meal or allowance, or certain travel allowances (including a meal portion), from an employee’s income as long as the value is reasonable (amongst other conditions). ...

LLC, but there were back-to-back agreements between USco and LLC, and between LLC and Canco under which LLC had committed under a forward subscription agreement with Canco to fund the interest payments under the loan, and USco had committed to make matching capital contributions to LLC – with CRA indicating that it had “resolved” this file “on the basis that paragraphs 247(2)(b) and (d) … and transfer pricing penalties applied.” ...

Consequently … A Co has a contingent right to be paid money from Drug Co. … A Co will make a supply of these same contingent rights to Finance Co. ...