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CRA responded: The following responses assume that where an arrangement is described as a joint venture in the question it has the characteristics of a joint venture as delineated in … P-103 …. ... With respect to the facts in this question: • The transfer by A to B of 25% interest would not meet the criteria for a section 167 election. • Assuming that B is transferring to C its entire interest when it transfers its 85% share, and that the supply is not from a registrant to a non-registrant, the supply would qualify for a section 167 election. • The transfer by A to C of its remaining entire 15% interest may qualify depending on the facts of the situation. ...

Excise and GST/HST News- No. 114, August 2023-- summary under Subsection 280(1) Summary Under Tax Topics- Excise Tax Act- Section 280- Subsection 280(1) P-194R2 cancelled in light of Villa Ste-Rose GST/HST Policy Statement P-194R2 Application of Penalties and Interest when a Return and/or Rebate Application, and/or Another Return, is Received After the Due Date was cancelled on May 10, 2023 …. [D]ue to decisions rendered … [in] Villa Ste-Rose … the policy is now obsolete. ...

Before concluding that the supply of the service would be in New Brunswick, CRA stated: A service and real property would generally be regarded as being in relation to each other pursuant to the above guidelines if the purpose of the service is to: • physically count the property; • appraise or value the property; • physically protect or secure the property; or • enhance the value of the property. ...

. … … [T]he Service Agreement provides, in part, that any notice or other communication to the Council shall be delivered or sent to:[…][Contact information of the Council]. … Under the rules above, the place of supply of the services supplied under the Service Agreement is [Province X]. To be a “practitioner” for purposes of the exemption in section 7.1 of Part II of Schedule V, paragraph (b) of the definition of “practitioner” provides that you must be registered with the regulatory body or professional college for dietitians practising in the province in which the service is supplied. … ...

In rejecting the Association’s submission that it collected its fees as Society membership dues as agent for the Society notwithstanding a statement in the Society’s by-laws that: “On behalf of the Society membership, […] [Districts, such as the Association,] shall pay to the Society an annual fee based on a per capita rate for each of its […] Members,” CRA confirmed its statements in a previous ruling letter to the Association that: [T]he bylaws of the [Society] provide no liability to the individual members to pay membership dues to [Society]. In particular, pursuant to section […] of the [Society]’s bylaws, the [District] organizations have the obligation to pay an annual fee to the [Society]. Although the amount of this fee is calculated based on the number of individual members, the individual members are not liable to pay this fee to the [Society]. … Therefore, the value of the consideration for [the Association]’s supplies of memberships is the entire amount charged by [the Association] to the individual members. ...

CRA responded: Our position on the interpretation of section 186 … has not changed. …[W] e would, for example, apply … the Miedzi case … where a particular situation has the same facts ….. ...

CRA stated: The … Priority Distribution is … a payment to [the manager] for performing the day-to-day supervision, management and operation of the Nursing Home [and it] is supplying these services to the participants in the joint venture. … [The manager] is reimbursed by the joint venture for the wages and salaries it pays to its employees. [The manager] makes a supply to the joint venture of the services of these employees [and] … is supplying these services to its co-participant [the charity]. ...

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed A proposed GST/HST amendment would zero-rate the supply of an ovum – which would have the effect of rendering the importation of an ovum as a non‑taxable importation. ... Respecting the application of the ovum amendment, for example, CRA indicates: [S]uppliers can stop charging GST/HST on supplies of human ova in accordance with the proposed amendment as of March 20, 2019. … [C]onsistent with its standard practice, the CRA is administering this measure on the basis of the proposed amendment [and similarly re … However, the CRA cannot pay a rebate for an amount paid in error as or on account of tax until the proposed amendment becomes law. A supplier who has charged or collected GST/HST on human ova supplied after March 19, 2019, must include that amount in the calculation of their net tax on their GST/HST return …. ...

. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. However … [t]he CRA is under no obligation to accept the value used by the general partner if it is determined to be over or under valued but it will consider the general partner’s FMV determination …. ...

. … For example, in the case of an annual bonus paid by an eligible employer to an eligible employee, it would generally be reasonable to consider that the annual bonus was earned throughout the fiscal period to which it relates. ... It would also be reasonable, for purposes of computing baseline remuneration, to calculate the average weekly eligible remuneration by dividing the bonus amount by the number of weeks included in the period to which it relates …. [Q.17-6] Apportionment of commissions To determine whether a commission payment is in respect of a specific week, it is necessary to review the complete set of facts pertaining to a particular situation, including the employment contract … [and] practices specific to a particular industry …. ...