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. … Quebec SLFI objection Effective January 1, 2013, the CRA administers the QST applicable to SLFIs. ...

S3-F3-C1- Replacement Property-- summary under Subsection 44(6) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(6) Reallocation under s. 44(6) 1.18 … [U]nder subsection 44(6), a taxpayer may be permitted to reallocate the POD of a former business property composed of land and one or more buildings between the land component and the building component. ...

. … Application of general rules 14. If these rules do not determine the place of supply of the transportation pass (for example, where the passenger transportation services covered by the passenger transportation pass may not always begin in the same participating province), the place of supply is determined under the general place of supply rules for intangible personal property. ...

In this case, a loss restriction event would occur as a result of the distribution of the shares – except that control of the corporation will be deemed not to have been acquired if the individual beneficiary was related to each of the three trustees immediately before the distribution of the shares. ...

. … [T]he redemption of the shares of the corporation is related to the commercial activities of the corporation. ...

IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) No penalty if tax remitted by Feb 15/based only on net annual increase in balance 38....If there is no series of loans or other transactions and repayments (see ¶ 28 above), the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the taxation year of the lender, in order to determine if the exception under subsection 15(2.6) applies. ...

Where renewal or extension periods are considered part of the life of the property under the criteria set out in ¶ 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ...

. … [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...

. … Tips and gratuities …A tip or gratuity that is freely given by a customer, for example, cash not recorded on a bill, is not subject to the GST/HST. ...

However, … paragraph 95(6)(b) could still apply in other contexts such as… the manipulation of a taxpayer's participating percentage in a controlled foreign affiliate. ...