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CRA stated: One of the conditions for making a section 167 election is that if the supplier is a registrant, the recipient must be a registrant … [which] is a question of fact … There is no provision deeming a predecessor (in this case, Newco) to acquire the characteristics of its successor Amalco. ...

4 December 2023 Canadian Tax Foundation Event Announcement-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income policy changes announced on 28 November 2023 are effective for taxation years commencing after that date On December 4, 2023, the Canadian Tax Foundation posted the following message on CRA's behalf regarding CRA’s oral presentation (with slides) made on November 28, 2023 entitled, “ S. 55(2) and Safe Income- Where Are We Now? ”: Pursuant to our presentation on Safe Income at the 2023 Annual Conference on November 28, 2023, all announcements that constitute a change in position will apply prospectively to calculations of safe income for taxation years beginning after November 28, 2023. ...

CRA News Release, “Bare trusts are exempt from trust reporting requirements for 2023,” 28 March 2024-- summary under Subsection 150(1.2) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2) Cancellation of bare trust reporting obligation for calendar 2023 In recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians, the Canada Revenue Agency (CRA) will not require bare trusts to file a … T3 return … including Schedule 15 (Beneficial Ownership Information of a Trust), for the 2023 tax year, unless the CRA makes a direct request for these filings. ...

. … Further, the prohibition on both "direct and indirect" partisan political activities is highly subjective (particularly "indirect"), and has been the subject of much confusion in the charitable sector…. ... Proposed amendment allowing charities to fully engage in non-partisan public policy dialogue and development that is subordinate to and furthers their charitable purposes (pp. 17-18) Recommendation 3 …The Panel recommends that amendments: retain the current legal requirement that charities must be constituted and operated exclusively for charitable purposes, and that political purposes are not charitable purposes; fully support the engagement of charities in non-partisan public policy dialogue and development in furtherance of charitable purposes, retiring the term "political activities" … and clearly articulating the meaning of "public policy dialogue and development" to include: providing information, research, opinions, advocacy, mobilizing others, representation, providing forums and convening discussions; and retain the prohibition on charities’ engaging in "partisan political activities", with the inclusion of "elected officials" (i.e. charities may not directly support "a political party, elected official or candidate for public office"), and the removal of the prohibition on "indirect" support, given its subjectivity. … The rationale for this approach is more fully described under Recommendation 1 in the context of interim changes recommended to the policy guidance. ...

CRA responded: Pursuant to … Polygon, Builder’s supplies are characterized as taxable supplies that are outside the scope of section 191 …. …[B]ecause Builder does not make (or hold the lots for the purposes of making) exempt supplies included in section 6 or 7 of Part I of Schedule V …, DeveloperCo’s subleases of the lots to Builder are exempt under subparagraph 7(a)(ii) of Part I of Schedule V as opposed to being exempt under section 6.1 of Part I of Schedule V. ...

An individual’s continuous occupancy of the dwelling unit for a period is not necessarily interrupted by the individual’s physical absence from the dwelling unit at a time in the period if both of the following apply: the individual still has the right to occupy the dwelling unit throughout their physical absence the right to occupy the dwelling unit is not given to another individual for any period during the physical absence Tests varying on whether an individual owner and whether a written lease No day can be counted more than once As explained above, if you are an affected owner that: is an individual, you can determine if there is a qualifying occupancy period for your ownership of a residential property as explained under one of the following headings: Type 1 qualifying occupants – individuals having agreements evidenced in writing Type 2 qualifying occupants – individual owners and their family is not an individual (such as a corporation), you can determine if there is a qualifying occupancy period for your ownership of a residential property only under the heading Type 1 qualifying occupants – individuals having agreements evidenced in writing In either case, your ownership of the residential property does not qualify for the exemption for qualifying occupancy unless at least 180 days in a calendar year are included in one or more qualifying occupancy periods for your ownership of the residential property. ...

. … Causal allocation 46. Causal allocation directly approximates the use of a particular business input using a logical and systematic approach and an appropriate allocation base. 47. ... An input-based allocation uses a calculation based on the procurative extent of other business inputs. … 51. ... Further, other distorting factors must be excluded from the ITC calculations in a revenue‑based method …. ...

. … When the vendor does not have to charge tax A different rule applies for used goods you accept as a trade-in from a person who is not required to charge GST/HST (usually a person who is not required to register for GST/HST). ... In this case, you generally charge GST/HST on the net amount of the sale or lease, that is, the price of the goods you sell or lease minus the amount you allow for the trade-in. … [S]ee GST/HST Technical Information Bulletin B-084, Treatment of Used Goods. ...

. … If the company's responsibility is limited to providing registered or licensed nurses to the facility so that the facility may satisfy its own staffing requirements, and the nurses are subject to the control of the operator of the facility and render services under the direction of the facility in accordance with the facility's responsibility to provide care to a patient or resident of the facility, the company has made a taxable supply of personnel or human resources, and not a supply of exempt nursing services. … However, if the company is responsible for the provision of nursing services to the patients or residents of the facility and is accountable for the quality of nursing care provided, the company may have made an exempt supply of a nursing service rendered by a registered or licensed nurse to an individual, where the service is provided within a nurse-patient relationship. ...

As discussed in the Excise and GST/HST Rulings memorandum issued […] on [mm/dd/yyyy] (RITS […]), where a receiver (such as a single asset receiver) is responsible for only a part and not all of the person's businesses, properties, affairs or assets, the receiver may use a sub-account of the person's GST/HST registration account for GST/HST purposes. ...