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Administrative Policy summary
GST/HST Memorandum 3-6 Conversion of Foreign Currency July 2018 -- summary under Section 159
Example 2 (re the day the foreign currency is acquired – occurring on date of money order purchase) On April 12, 2017, a non-resident … invoiced a Canadian GST/HST registered recipient of a supply for $1,000 US, for a taxable supply made in Alberta that was subject to the GST at a rate of 5%. ... Acceptable exchange rate sources 13. … [A] person may use the exchange rate from: the source used for an actual conversion (that is, the source where the foreign currency was exchanged for Canadian dollars) the source the person typically uses for actual conversions a Canadian chartered bank the Bank of Canada the rate provided by the … CBSA … for purposes of converting the value for duty of imported goods Example 4 (regular use of a local U.S. bank for FX exchange) … [A U.S.] company regularly uses the services of a local American bank to exchange US currency for foreign currencies and vice versa. Since the company regularly uses the local bank to exchange currencies, the local bank is an acceptable exchange rate source Example 5 (database service not an acceptable source) The company … subscribes to a database service that tracks and reports currency exchange rates, including rates on the interbank market, rates set by the Bank of Canada, and average rates offered by Canadian chartered banks. ...
Administrative Policy summary
GST/HST Memorandum 20-7 “Second-language Instruction” December 2019 -- summary under Section 11
. … The exemption does not apply to other courses relating to English or French, such as courses intended to help students improve their command of English or French when it is their first language, nor does it apply to the supply of instruction in languages other than French or English. ... Operated test 23. … The CRA will consider a business to be operated primarily to provide instruction in languages if more than 50% of its total annual revenues are derived from fees/tuition for, or can be attributed to instruction in, language courses. … 26. … [I]f the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...
Administrative Policy summary
17 September 2018 Ruling 182403 -- summary under Paragraph (f)
Accordingly, the Distributions, as payments of money in respect of the Partners' interests in the Limited Partnership, are financial services under paragraph (f) …. When the Partnership provides the payment of a Distribution to a Partner, the Partnership is making … an exempt supply … unless the supply is zero-rated …. ...
Administrative Policy summary
GST/HST Memorandum 20-5 “School Cafeterias, University and Public College Meal Plans, and Food Service Providers” December 2019 -- summary under Section 13
Based on the average retail price per meal at the university, the single amount paid by a student is sufficient to provide the student with at least 10 meals each week for the period of the plan ($7.25 × 10 meals × 34 weeks = $2,465). ...
Article Summary
Martin Marcone, "Resolution Procedures for Intergovernmental Transfer Pricing Disputes: Part 2", 23 Can. Current Tax", Volume 23, Number 12, September 2013: -- summary under Article 26
. …] However, as indicated above, a precondition to arbitration is that a court in either country has not ruled upon the unresolved issues. ...
Article Summary
Peter Megoudis, "The Canadian Non-resident Trust Rules and Global Employee Benefit Plan Trusts", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24, No. 3, October 2012, p. 1583. -- summary under Subsection 94(3)
. … It may be reasonable to view the custodian's holding of investment shares as an agency or bare nominee arrangement, and its holding of matching shares as more closely resembling that of a trust. ...
Article Summary
Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231 -- summary under Subsection 91(4.7)
Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231-- summary under Subsection 91(4.7) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(4.7) After referring to the expansion of the income test in s. 91(4.1)(a) by virtue of the deductible dividend test in s. 91(4.7), they stated: … On this basis, the income test could apply to investments that may not be considered hybrid instruments in the conventional sense. ...
Article Summary
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Tangible Personal Property
. … If there is a large degree of affixation, the good either becomes incorporated into the real property as an improvement to the real property or it becomes affixed machinery. ...
Article Summary
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Investment
[T]he CRA has given an example [fn 34: … 2009-0309281E5 …example 4)] illustrating how the possibility of publicly traded common I shares being characterized as an investment for the purposes of the SIFT rules would be reduced if, among other factors, the corporation is a large corporation with other sources of income; the partnership earnings represent a relatively small component of the corporation's business; and the partnership interest is not exchangeable for shares of the corporation. ...