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Example 24 – Services acquired in participating province for partial use in another participating province In a claim period, a non-registrant PSB resident in Nova Scotia purchases advertising services in Nova Scotia for $5,000, on which it pays $750 in HST ($5,000 × 15%). ... The federal part of the HST paid in respect of the advertising services is $250 ($750 × 5/15). ... The provincial part of the HST paid in respect of the advertising services is $500 ($750 × 10/15). ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...

. … … Rosenberg … addresses the binding nature of an agreement reached between the CRA and a taxpayer provided that neither party breaks their commitment to the agreement, and provided that the fact pattern relied upon in reaching the agreement does not change. Binding audit agreement requires full disclosure and waiver For the audit agreement to be binding, the taxpayer must: disclose all material facts in elections, returns, applications, and other submissions as applicable, related to the issue(s) dealt within the audit agreement; waive their right to object to the assessment of the issue(s) and provide a signed copy of the Waiver of Objection Rights to the CRA; and in some instances, agree to pay the resulting taxes, penalties and interest owing as a result of the agreed upon assessment within the timeframes specified in the audit agreement. … The waiver is a statement voluntarily signed by a taxpayer, or an authorized representative, to the effect that the taxpayer gives up both the right to object to, and to appeal, one or more issues identified in the audit agreement and set out in the waiver. ... Waiver signifies that no further recourse The waiver must contain statements to the effect that:… the impact of … subsection 165(1.2) of the ITA or subsection 301(1.6) of the ETA … have been explained and are understood to mean that no further recourse to any authority with respect to the assessment by the CRA of the waived issues is available upon signing the waiver. ...

Example 2 (re the day the foreign currency is acquired – occurring on date of money order purchase) On April 12, 2017, a non-resident … invoiced a Canadian GST/HST registered recipient of a supply for $1,000 US, for a taxable supply made in Alberta that was subject to the GST at a rate of 5%. ... Acceptable exchange rate sources 13. … [A] person may use the exchange rate from: the source used for an actual conversion (that is, the source where the foreign currency was exchanged for Canadian dollars) the source the person typically uses for actual conversions a Canadian chartered bank the Bank of Canada the rate provided by the … CBSA … for purposes of converting the value for duty of imported goods Example 4 (regular use of a local U.S. bank for FX exchange) … [A U.S.] company regularly uses the services of a local American bank to exchange US currency for foreign currencies and vice versa. Since the company regularly uses the local bank to exchange currencies, the local bank is an acceptable exchange rate source Example 5 (database service not an acceptable source) The company … subscribes to a database service that tracks and reports currency exchange rates, including rates on the interbank market, rates set by the Bank of Canada, and average rates offered by Canadian chartered banks. ...

When asked to comment on this position being contrary to Fraser International, which held that a private college was “affiliated” with a university, and hence qualified as a “university”, even though the parent organization (Simon Fraser University) did not grant degrees to graduates of that college, CRA stated: Th[is] lack of reference to … Fraser International … is an oversight on our part. We thank you for bringing this to our attention. … [T]he CRA is reviewing Memorandum 20-3 to include additional information on whether an organization operating a college affiliated with a university qualifies as a university …. ...

Example of application to services provided under active direction of sub 2.69 … Example 3 – Central paymaster rules Corporation A provides services to …[its subsidiary] Corporation B … of a type that could reasonably be expected to be performed by employees of the Corporation B in the ordinary course of its business. In this regard, Employees of Corporation A report to a permanent establishment of Corporation B, receive direction from Corporation B’s corporate structure, and all or substantially all of the Employees’ economic activity is for the benefit of Corporation B. … For the purposes of Part IV of the Regulations the salaries and wages of Corporation A’s Employees would be attributed to Corporation B’s salaries and wages paid in the year. ...

See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. V, No. 3, pp. 21-23 (April 1991), at p. 22., which states in respect of “Intercorporate Transactions” (in part): … [A]s an administrative concession, Revenue Canada stated that it would not apply the anti-avoidance rule in section 155 to any of the transactions between the various corporations, in order that the transactions could be completed for nil or nominal consideration. ...

IT-170R "Sale of Property- When Included in Income Computation"-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (e) Dispositions reference changes of beneficial ownership ¶ 4. Subparagraph 54(c)(v) [similar to what now is s. 248(1) – disposition – para. ...

Examples of acceptable variations – COLA Many RPPs provide cost-of-living adjustments that are based on the full Consumer Price Index (CPI). ... Commutation of PV of RPP benefits to acquire life annuity [T]he terms of the plan … might allow a member to use their commuted value to buy a life annuity from a licensed annuity provider. … A commuted value cannot be used to purchase an annuity that is materially different from the RPP, based on the plan as registered. ... Any excess must be distributed on a taxable basis If the commuted value is greater than the cost to buy an annuity that replicates the RPP benefits, the excess commuted value cannot be used to provide higher annuity payments under the annuity contract. … Under [Reg.] 8502(d)(ix) … the portion of the commuted value that is in excess of the annuity acquisition cost can be paid in cash to the individual and must be included in income for tax purposes. … Use of excess assets e.g., in IPP to purchase further benefits If there are excess assets in the RPP, to the extent that lifetime retirement benefits and ancillary benefits are not at the maximum allowable under the Act, benefits can be enhanced through a plan amendment before being settled by an annuity purchase. ...

. … "Rent-to-own" vs "sale" Policy statement P-164 … 16. … Because the self-supply rules apply only where there is a supply by way of lease, licence or similar arrangement, it is necessary to determine if a rent-to-own agreement represents a supply by way of sale or a supply by way of lease, licence or similar arrangement. ...