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IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993-- summary under Subsection 147(10.1) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(10.1) 14. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ... V – Service Related to Intangible Personal Property")-- summary under Section 10.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 10.1 A Canadian GST-registered supplier sells custom software that it has been using to perform a service electronically, with such supplies being made in Canada. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 16. ("Constructive Importer Rules – Section 178.8")-- summary under Subsection 178.8(2) Summary Under Tax Topics- Excise Tax Act- Section 178.8- Subsection 178.8(2) A resident registered corporation (Corporation A) entered into an agreement with a resident registered corporation (Supplier) for the purchase of a power facility the components of which were to be imported from abroad. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services")-- summary under Section 16 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 16 A GST/HST-registered Canadian law firm performs legal services, as a single, bundled supply, on behalf of a Canadian lender in a secured financing transaction, where the security for the loan is registered under the Personal Property Security Acts in five Canadian provinces against the borrower's tangible personal property, including inventory. ...

15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations”-- summary under Subsection 95(8) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(8) Finance has issued a comfort letter respecting umbrella corporation interests where there is no tax avoidance purpose It is not clear to Finance that the compliance burden on a Canadian investor under the tracking interest rules is unusually onerous compared with other compliance obligations under this part of the Act. ...

May 2019 CPA Alberta CRA Roundtable, ITA Session – Q.7-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) “in contemplation of” can be backwards looking What factors would CRA typically review to assess whether certain transactions are part of the same series; and how important is it that transactions were carried out at, or around, the same time? ... Per … Copthorne …: ``… The fact the language of s. 248(10) allows either prospective or retrospective connection of a related transaction to a common law series and that such an interpretation accords with the Parliamentary purpose, impels me to conclude that this interpretation should be preferred to the interpretation advanced by Copthorne…`` The text and content of s. 248(10) have left open when the contemplation of the series must take place as nothing in the text specifies when the related transaction must be completed in relation to the series. ...

CRA indicated: [T]he cleaning products are incidental to the services, since they were used in providing the services [so that] the incidental goods amount … would not be subtracted from the service part of the gross business income i.e., 100% of its revenue would be services revenue. ... Example 6 (separate charges of deck construction company for labour and materials are respected) A corporation engaged in the design, construction and repair of decks supplies all materials and labour when constructing and repairing the decks – and for a fee, also designs decks and provides plans to customers who want to build the deck on their own. Gross business income of the corporation (2017): $200,000 made up as follows: Deck construction: $175,000: Materials $90,000 Labour $85,000 Deck repairs: $20,000: Materials $10,000 Labour $10,000 Deck design: $5,000 Gross business income for services: $100,000 ($200,000 − $90,000 − $10,000) Gross business income test: $100,000 ∕ $200,000 = 50% Since less than 90% of the business income from all activities of the corporation is for services, the condition in subparagraph 120.4(1)(a)(i) of the definition of excluded shares is met. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.4(7) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(7) Notifiable Transactions Reasonable expectation to know – no reporting Only advisors who know or are reasonably expected to know of their reporting requirements are required to file – for example, this generally would not extend to “more junior employees and those who have limited roles that do not give them visibility of the broader transaction or series as well as the associated tax treatment and tax benefit” even if their employer did not file. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.4(6) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(6) Notifiable Transactions Due diligence- notifiable transactions – no reporting “A person who obtained the tax benefit would generally meet their due diligence obligations by asking their advisors about potential reporting obligations that might arise from the transactions (and being informed by their advisors that no such reporting obligations will arise on account of the transaction being a notifiable transaction or substantially similar to a notifiable transaction).” ...

GST/HST Memorandum 3-3-3, Place of Supply in a Province – Tangible Personal Property, August 2024-- summary under Section 1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part II- Section 1 Where Manitoba supplier personally delivers good to consignee in Ontario, who sells the goods to Quebec purchaser and has it couriered there, there are 2 supplies: in Ontario, and Quebec Example 9 – Delivery of goods sold on purchase/resale consignment basis A consignment sale under a purchase and resale arrangement is treated as two separate supplies that occur at the time the consignee sells the good to the final purchaser. ... Supply 1 – Sale by the Manitoba company to the consignee The sale of the good from the Manitoba company to the consignee is made in Ontario and is subject to the HST at a rate of 13% because the Manitoba company delivered the good to the consignee in Ontario. Supply 2 – Sale by the consignee to the final purchaser The second supply is the sale of the good from the consignee to the final purchaser. ...