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. … A person shares mining payments when the person shares in the risk of success in the mining activities of the group. … Where a person receives a direct share of the actual mining payment, or a payment or adjustment that is determined based on the actual mining payment earned by the pool or the operator, the person is generally considered to share in the mining payments. ... Another factor to consider in determining whether persons share mining payments within a mining group is whether the operator charges fees to persons with respect to the management or administration of the mining endeavours. … [T]he following types of arrangements for mining would be indicative of a person and a mining pool operator not being members of the same mining group for the purposes of section 188.2: The person is paid by the mining pool operator for the contribution of computing resources by the person and the payment is based on the expected value of the number of blocks validated calculated based on the expected block subsidy regardless of whether the activity gives rise to an actual block subsidy or transaction fee [and similarly where such expected value also includes expected transaction fees]. … Such [person’s] supply is subject to the general GST/HST rules ….. ...

. … The CRA believes firmly that all participants in offshore tax evasion and tax avoidance schemes must be identified and brought into full compliance with their tax obligations. ... …There is no preferred treatment of certain taxpayers who are non-compliant over others. … …Where appropriate, including with matters before the courts, and in consultation with the Department of Justice, the CRA seeks to resolve matters through a settlement offer that is based on facts and in accordance with the law. ... Over $7 billion of that amount – about two-thirds – involves international and large business aggressive tax planning, including high net worth individuals and multi-nationals. ...

. … a location may not be a RPE for an individual if, for example, the individual works at that particular location only once during the year or perhaps for only a few days in the year. … The CRA’s general position is that travel between an employee’s home and their employer’s business location is personal, even when the employee has a home office that is a regular place of employment. … CRA does not have a list of common factors used to determine if a work location is an RPE. … [F]or a location to be considered a special work site…: 1. ...

In its explanation, CRA briefly described satisfaction of the “qualifying funding" requirement in s. 259(2.1) as well as the facility accreditation requirement in s. 259(2.1)(c) (here, by the MOHLTC), and focused on the “facility supply” requirement, stating: Elim Housing … made the determination that Elim was entitled to claim the 83% PSB rebate as a facility operator operating a qualifying facility based on the presence of the following elements which indicated Elim to be making facility supplies: all of the residents had conditions that required “complex care” …; the residents were extremely dependent on care either by reason of mental or physical impairment …; residents were under the care of a physician, who was either associated with the facility or had a pre-existing relationship with the resident; a tailored care plan was created for each resident, documented and implemented: … physicians visited residents frequently (e.g., roughly on a bi-weekly basis); physicians were at, or on-call to attend, the facility at all times; physicians provided substantial medical care (e.g., addressed medical concerns, participated in medication reviews, attended interdisciplinary meetings); registered nurses were at the facility at all times, and nurses were in regular communication with physicians for prescription or advice; the facility received funding for 2.8 hours of care per resident per day (the calculation was based on scheduled staffing hours); the care provided was of a different type than ordinary assistance with activities of daily living that a more robust individual might require. ...

(a) Can Aco now make a voluntary disclosure in light of para. 30 of GST/HST Memorandum 16-5, which indicates that a VDP application will not be considered voluntary if, “enforcement action … relating to the subject matter of the VDP application has been initiated … against a third party, where the purpose and impact of the enforcement action against the third party are sufficiently related to the present application”? ... CRA responded: As per … Memorandum 16-5 [para. 77], the applicant will be required to waive their rights to object to the assessment results in regards to the specific information submitted in the VDP application. However, the applicant is allowed to file a Notice of Objection in case of disagreement with respect to characterization issues, such as whether a supply is a taxable or exempt supply, or whether a particular supply is deemed to be made inside or outside Canada as a result of the application of the place of supply rule in section 144 …. ...

. … The exemption does not apply to other courses relating to English or French, such as courses intended to help students improve their command of English or French when it is their first language, nor does it apply to the supply of instruction in languages other than French or English. ... Operated test 23. … The CRA will consider a business to be operated primarily to provide instruction in languages if more than 50% of its total annual revenues are derived from fees/tuition for, or can be attributed to instruction in, language courses. … 26. … [I]f the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...

25 March 2021 CBA Commodity Taxes Roundtable, Q.13-- summary under Subsection 301(3) Summary Under Tax Topics- Excise Tax Act- Section 301- Subsection 301(3) procedure followed where further Audit input is desired or required by Appeals (a) Where additional documentation becomes available after an objection is with the appeals officer, must that officer review and analyze the additional documentation, or should it be sent to Audit for review and, if so, to the original auditor – and does the taxpayer have a say? ... CRA responded: (a) … Upon receipt of the additional information/documents from a taxpayer, Appeals will review the documents and determine whether further audit work, examination or analysis is required. ... (b) In situations where specific documents or information was requested by the auditor, but only provided by the taxpayer at the objection stage, the appeals officer is required to make a referral to audit … [although] the GST/HST Refund Integrity Program is excluded from this mandatory referral process …. ...

. … The phrase any other purpose except profit is interpreted as a catch-all for other associations that are organized and operated for other than commercial or financial reasons. Permitted accumulation of funds for building replacement etc. 9. … [I]n certain cases, when an association requires a time period in excess of the current and prior year to accumulate the funds needed to acquire a capital property that will be used to achieve its declared exempt activities, the association's tax-exempt status may not be affected. ... Also included are payments made to employees or members of the association to assist them in covering their expenses to attend various conventions and meetings as delegates on behalf of the association, provided attendance at such conventions and meetings is to further the aims and objectives of the association. … ...

. … Currently, the profession of acupuncture is regulated under provincial legislation in the provinces of British Columbia, Alberta, Ontario, Quebec and Newfoundland and Labrador. If an acupuncture service is supplied in any of these provinces, the acupuncturist is required to be licensed by the regulatory body for the profession of acupuncture in that province in order to be a “practitioner” for GST/HST purposes (e.g., College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario). … [I]f an acupuncturist makes a supply of an acupuncture service in [other provinces]…the acupuncturist is required to have qualifications equivalent to those qualifications required to be licensed in a province where the profession is regulated…. Psychotherapy services Currently, there is no provision in the Act that specifically exempts from the GST/HST supplies of psychotherapy services or services rendered by a psychotherapist, even if the psychotherapist is licensed and renders the service in a province that regulates the profession of psychotherapy. … [S]upplies of psychotherapy services rendered to an individual by a licensed physician or registered nurse, social worker, psychologist or occupational therapist will be exempt from the GST/HST if the supply meets the requirements in the relevant exemption and the supply is also a qualifying health care supply…. ...

. … 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. ...