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V, and was subject to GST/HST, CRA stated: … The consideration paid or payable must be directly linked to a supply of a health care service that is in fact rendered by a physician to a particular individual. … … [T]he hospital acquired a right to call upon the physician to attend the hospital during a given time period. ... …For purposes of the GST/HST, “property” is defined in subsection 123(1) to mean any property, … and includes a right or interest of any kind …. As consideration for a supply of “property”, the hospital on-call fee is not consideration paid or payable for a supply of a service for GST/HST purposes. … CRA went on to note: If a physician’s only taxable income is generated from hospital on-call fees and these fees do not exceed the small supplier threshold, the physician would qualify as a small supplier and as such not be required to register and charge GST/HST on this fee. ...

Note: on the RC4649, the reporting entity is either: • the UPE • an SPE – a Canadian CE that has been designated as a surrogate parent of a foreign UPE. Note: A Canadian CE cannot be designated as an SPE of a Canadian UPE • a CE, in cases of a local filing requirement Filing obligations of Canadian CE that is SPE Obligations of a surrogate parent entity in Canada A CE resident in Canada that is appointed as an SPE of a foreign UPE is subject to filing requirements as if that entity were a UPE in Canada. In particular, subsection 233.8(1) of the Act defines an SPE as a CE of an MNE group that has been appointed by the MNE group — in substitution for the UPE — to file the CbC report on behalf of the MNE group, if one or more of the conditions in subparagraph 233.8(3)(b)(ii) applies (i.e., the conditions for the secondary reporting mechanism to apply). ...

Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021-- summary under Top-Up Percentage Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Top-Up Percentage [Q.20-3] Table of top-up percentages Top-up percentage examples for claim periods 5 to 9 Top-up revenue reduction percentage Top-up percentage Top-up percentage= 1.25 x (top-up revenue reduction percentage – 50%) 70% and over 25% 1.25 x (70%- 50%) = 25% 65% 18.75% 1.25 x (65%- 50%) = 18.75% 60% 12.5% 1.25 x (60%- 50%) = 12.5% 55% 6.25% 1.25 x (55%- 50%) = 6.25% 50% and under 0.0% 1.25 x (50%- 50%) = 0% The overall wage subsidy percentage would be equal to the top-up percentage plus the base percentage. ...

. … [R]egistered charities that wanted to work through a non-qualified donee [formerly] could only do this in one way. Charities had to show that the activities were their own, demonstrated by maintaining ongoing direction and control over the use of their resources. 2. … With [the enactment of the qualifying disbursement rules], charities can support the activities of non-qualified donees (grantees), provided charities can show that they meet accountability requirements set out below. … 12. … [A] charity continues to be able to carry on activities using an “intermediary”, provided the charity exercises “direction and control”. … 14. ... With pooled grants, the CRA’s requirements focus on the charity implementing the following accountability tools: … ...

Determination of partnership status of foreign partnership by reference to provincial law 20. … Continental Bank … Backman … and Spire Freezers confirmed that the existence of a partnership must be determined by reference to the relevant partnership law of the province or territory and this is the case even when dealing with a partnership established in a jurisdiction outside Canada. ... In addition, express declarations against the existence of a partnership will not be determinative if the facts indicate otherwise. … 31. ... A partnership is distinguished from … other types of relationships and arrangements [which] include joint ventures, co-ownership relationships, and fee-sharing and cost-sharing arrangements. … Whether a partner in a foreign limited partnership need contribute capital 74. … [L]egislation in certain jurisdictions of other countries may permit the formation of a partnership having a legal personality distinct from its members, with limited liability for debts and obligations afforded to all members, including the general partner. ...

However, there is no time limitation for assessing the following penalties: • the 6% penalty assessed under section 280; • the failure-to-file penalty under section 280.1; • the penalty for false statements and omissions under section 285; and • the third party penalty under section 285.1. ...

Applications received prior to October 1, 2025, will be considered for the VDP relief outlined in … IC00-1R6 …. ... However, if the errors or omissions relate to assets or income that are located outside Canada, documentation for the most recent ten (10) years must be included. … 29. … In cases where books and records do not exist, taxpayers should make all reasonable efforts to provide estimates. … Payment 32. For an application to be granted relief, payment, or a request for a payment arrangement of the estimated taxes owing must be made, if it applies. … CRA decision … 35. ...

. … The CRA…will generally exercise administrative tolerance if this issue is … reported by the registrant or discovered … on audit. ... Pursuant to subsection 296(2) … the Minister must take into account an ITC for a particular reporting period when assessing the net tax for that reporting period even though the time limit for claiming the ITC may have expired. ... Administrative tolerance will not be granted where the purchaser is not entitled to claim a full ITC or where the purchaser has already claimed the ITC in a GST/HST return … [nor] where the purchaser was previously assessed under similar circumstances. ...

CRA responded: [T]he formula outlined in paragraph 254(2)(i) … makes reference to the “total consideration” … described in paragraph 254(2)(c) … [as] the sum of the consideration payable for the housing itself (that is, the purchase price of $250,000) and the consideration payable for any other taxable supply of an interest in the housing (that is, the assignment fee of $150,000). ... A [instead] were not a builder, his assignment of the agreement of purchase and sale would be an exempt supply … and the consideration for the exempt assignment would not be included in determining the “total consideration” as described in paragraph 254(2)(c). … ...

8 September 2017 Interpretation 180362-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 supply made when master sales agreement entered into S. 144 provides that “a supply of goods that have been imported … but have not been released [by the CBSA] before the goods are delivered … to the recipient of the supply, shall be deemed to be made outside Canada,” so that even if the vendor is a registrant, it is not required to charge GST/HST. ... In this regard, CRA stated: Under section 133, the supply of the goods is deemed to be made when the agreement for the supply of the goods is entered into. … The relevance of the timing of when a supply is made under section 133 to the application of section 144 is reflected in the wording of the definition of "specified supply" of goods under subsection 178.8(1) … [which] distinguishes between a supply of goods that are imported after the supply is made, and a supply of goods that have been imported in circumstances in which section 144 deems the supply to have been made outside Canada. … ...