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. … 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. … [S]hipments of fuel oil to CanCo commenced only after the agreement for the supply was reached …. ...

Accordingly, the Distributions, as payments of money in respect of the Partners' interests in the Limited Partnership, are financial services under paragraph (f) …. When the Partnership provides the payment of a Distribution to a Partner, the Partnership is making … an exempt supply … unless the supply is zero-rated …. ...

. …. The TCC determined that Zomaron delivered to the acquirer/processor fully negotiated merchants requiring card payment processing services. … The TCC determined the predominant element in respect of this single supply to be “arranging for” the card payment processing services offered by the acquirer/processor to the merchants and that this “arranging for” activity was a financial service. … Although a supplier may be registered as an ISO/MSP within the Visa/Mastercard networks, the supplier may not always perform the very same services and have the very same obligations and autonomy as another ISO/MSP. … The CRA will only apply the Zomaron decision to supplies made by an ISO/MSP if the same fact situation exists. ...

11 April 2016 CRA Press Release “Government of Canada cracks down on tax evasion”-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) expansion of audit review of aggressive tax avoidance and evasion/embedded lawyers [T]he Government of Canada will invest over $444 million to enhance the Canada Revenue Agency’s (CRA) ability to detect, audit, and prosecute tax evasion – both at home and abroad. …This will result in a twelve-fold increase in the number of tax schemes examined by the CRA…[and] will increase the number of examinations focused on high-risk taxpayers – from 600 per year to 3000 per year – and will bring in $432 million in new tax revenue. ...

. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

. … Copper IUDs have a plastic frame that is wound around with copper wire or has copper sleeves. … [H]ormonal IUDs available in Canada contain the drug levonorgestrel which is on the list established under subsection 29.1(1) of the Food and Drugs Act and require a prescription from a physician to be purchased. … Therefore, the supply of hormonal IUDs is zero-rated pursuant to paragraph 2(b) of Part I of Schedule VI…. ...

. … No GST/HST collectible by CMHC on forgivable loans There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … ...

. … (e) The later accounting of the transactions by all parties is as if the election was made … 57. A request will not be accepted in the following cases: (a) It is reasonable to conclude that the taxpayer made the request for retroactive tax planning purposes. … (c) It is reasonable to conclude that the taxpayer had to make the request because he or she was negligent or careless to comply with the law ...

. … 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. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

. … 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. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...