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. … If the contracting address of the recipient is not obtained, the business address of the recipient that is most closely connected with the supply would be the obtained business address of the recipient in Canada that the supplier has the most contact with and that the supplier mostly uses in connection with that supply.... ...

For example, when: … all returns have been filed up to the date of dissolution, the articles of dissolution indicate that the corporation will distribute its assets to the shareholder(s) after satisfying its creditors, and immediately prior to the dissolution, it was owned by a sole shareholder and it has been determined that the shareholder is the rightful owner of the funds and the sole shareholder completes and returns a signed "Release and Indemnification" form to the CRA; or it was owned by multiple shareholders and a legal representative, as defined in Section 248(1) of the Income Tax Act, has been appointed by the shareholders, to act on their behalf and the appointed legal representative completes and returns a signed "Release and Indemnification" form to the CRA. ...

. … The Developer has only an interest in the Unit constructed on the Lot and cannot therefore dispose of something more (i.e., the Developer cannot make a separate sale of the building portion of the Unit). ...

. … The Developer has only an interest in the Unit constructed on the Lot and cannot therefore dispose of something more (i.e., the Developer cannot make a separate sale of the building portion of the Unit). ...

. … The CRA would generally review available documentation such as business plans or input tax credit claims and activities undertaken by the registrant to make taxable supplies such as research and marketing that support the expectation that the registrant will be making taxable supplies throughout the twelve months and that property acquired by the registrant within the twelve months is for use exclusively in its commercial activities. ...

. … [T]he employer is entitled to claim an ITC in respect of the tax payable to the investment manager to the extent the investment management service is acquired for supply to the plan trust in the course of the employer’s commercial activities, provided that all of the conditions of section 169… are met. ...

When the sham argument is used to support an audit assessment, AGP – HQ is informed and works closely with the TSO in ensuring the two elements of sham are demonstrated and that our position is well supported. ...

. … To the extent that the U.S. taxes are not used for claiming a foreign tax credit, they may be deducted under subsection 20(12)…. ...

The changes to s. 55(2) were meant to address the type of planning raised by D & D Livestock, where ACB is created (without being caught by existing s. 55(2) because there was no gain on the shares in question). ...

. … Accordingly, the supply of an IME by a medical practitioner is exempt under section 5…. ...