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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 1-- summary under Section 1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 1 prosecution or civil remedy Where the taxpayer has failed to provide information pursuant to a requirement under s. 289.1, "CRA's general policy is to proceed with a compliance order under section 289.1 (civil court remedy) prior to seeking the prosecution provision under section 326.) ...

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014-- summary under Section 14 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 14 Example 8 A manufacturer in Canada charges its customers for moulds required in manufacturing a specific product. ...

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998-- summary under Section 10 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 10 Example-zero-rating of global database (para. 51) Canadian company sells the international rights to operate a global database to a foreign company who pays the royalties to the Canadian company. ...

Alexandra MacLean, "CRA Audits of Large Corporations- The view from ILBD" under Responses to recent adverse decisions – Cameco, 27 November 27 2018 CTF Annual Conference.-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) no impact of Cameco (under appeal) on s. 247(2) application Cameco, which is under appeal, has not affected the CRA operation of its transfer pricing audit program (business as usual). ...

CBA National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 25-- summary under Section 3 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part II- Section 3 carriage arranged by customer CRA noted that s. 1 rather than s. 3 applied where the Ontario customer rather than the Quebec vendor arranged for the common carrier to ship the goods in question. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.3(2) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(2) Footnote 2 (re "straddle transactions") If a person enters into a series of transactions that straddle the effective date of designation, the reporting requirement will be triggered with the first transaction entered into after the effective date of designation that is part of a series of transactions that is the same as, or substantially similar to one that is designated at that time by the Minister. ...

"CALU Ques. 13-Buy-Sell Agreement & Valuation of Shares")-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares Where a corporation is required under a bona fide shareholders' agreement to pay life insurance proceeds as a capital dividend either to the estate of the deceased or to the surviving shareholders, such provision would be determinative of value as stated in paragraphs 28-31 of IC89-3, so that in valuing the share sold the fair market value of the life insurance proceeds would be offset by the liability to pay the dividend. ...

IT-359R2 "Premiums and Other Amounts with Respect to Leases " 20 December 1983-- summary under Contract or Option Cancellation Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

IT-359R2 "Premiums and Other Amounts with Respect to Leases " 20 December 1983-- summary under Leases and Licences Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 15-- summary under Registrant Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Registrant opening of account to process imported taxable supply assessments is not registration If an FI is not required to register for GST/HST purposes and chooses not to register voluntarily, it would not be a GST/HST registrant by virtue of an account that has been opened for the purpose of processing a self-assessment of GST/HST under Division IV. ...