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Article Summary
Jim Samuel, "Interaction of the Foreign Affiliate Surplus and Safe-Income Regimes: Selected Anomalies, Issues, and Planning Considerations", Canadian Tax Journal, (2018) 66:2, 269-307 -- summary under Paragraph 55(5)(d)
[fn 64: See… Brelco Drilling … [and] 2001-0093385] If a deficit of a lower-tier foreign affiliate does indeed reduce safe income on hand, the location of the deficit affiliate in a chain of foreign affiliates does not seem to be relevant—contrary to the general framework of the foreign affiliate surplus regime, in which so-called blocking deficits in a chain of foreign affiliates are generally more relevant (and potentially more problematic) than deficits in foreign affiliates that are at the bottom of the ownership chain. ... As a result, if one foreign affiliate in a chain has a hybrid surplus pool with an insufficient amount of hybrid underlying tax applicable [fn 66: …[D]efined in … 5907(1).] whereas another affiliate has an excess of hybrid underlying tax applicable, that pool is not available for the purposes of the determination of safe income, notwithstanding that the hybrid surplus would be fully sheltered with hybrid underlying tax applicable if the surplus pools of those two affiliates were combined. ...
Administrative Policy summary
GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017 -- summary under Subsection 175(1)
The volunteer paid $200 plus $26 in HST ($200 × 13%) for the car rental. ... The tax the charity is deemed to have paid in respect of the supply is equal to A × B where A is $26 – that is, the tax paid by the volunteer, B is 40% which is the lesser of 40% – that is, the percentage of the cost to the volunteer that was reimbursed, and 40% – that is, the extent expressed as a percentage to which the rental of the car was acquired for use in relation to activities of the charity. Therefore, the tax deemed paid by the charity for the car rental is equal to $10.40 ($26.00 × 40%). ...
Administrative Policy summary
GST/HST Memorandum 20-6 “Tutoring and Equivalent Services” December 2019 -- summary under Section 2
All levels of such music lessons are exempt and they are not subject to the immediate mandatory prerequisite requirements … in paragraph 9(c) …. ...
Administrative Policy summary
Excise and GST/HST News - No. 107 February 2020 -- summary under Section 7
New policy on “university” As a result of … Alexander College … a “recognized degree-granting institution” will now include a college or similar organization that is authorized by a province under provincial legislation or a governmental body in a foreign entity’s home jurisdiction to grant a degree where degree is defined in the applicable legislation to include an academic achievement at the associate level or higher. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.8 -- summary under Subsection 273(1)
CRA responded: Based on … the operator … not hav[ing] an interest in the real property on which the MURC is situated, the operator does not meet the conditions set out in paragraph (a) of the definition of “builder.” ...
Administrative Policy summary
Memorandum 8-3 - "Calculating Input Tax Credits" -- summary under Subsection 169(1.1)
The remaining 40% of the services are not improvements to capital property, and are to be expensed for income tax purposes. … Therefore, the GST deemed payable for the improvements to the apartment building is $300 (i.e., $500 × 60%). The ITC available on the improvement is calculated in accordance with subsection 169(1) and paragraph (b) of element B of the formula in that subsection, and is equal to $60 (i.e., $300 × 20%). ... However, if the repair services were partly (e.g., 20%) for consumption or use in commercial activities and partly (e.g., 80%) for consumption or use in non-commercial activities, an ITC of $40 (i.e., $200 × 20%) could be claimed in accordance with subsection 169(1) and paragraph (c) of element B of the formula in that subsection. ...
Administrative Policy summary
Excise and GST/HST News - No. 114, August 2023 -- summary under Section 154
Excise and GST/HST News- No. 114, August 2023-- summary under Section 154 Summary Under Tax Topics- Excise Tax Act- Section 154 Vancouver’s additional 2.5% hotel tax will increase the overall rate to above the 12% specified rate, thereby causing GST to be applied to the 13.5% provincial tax From February 1, 2023, until January 31, 2030 (effective period), the Major Events Municipal and Regional District Tax (Major Events MRDT) of 2.5% will apply to supplies of short-term accommodation made in the City of Vancouver … in addition to the 8% provincial sales tax (PST) and the 3% Vancouver Municipal and Regional District Tax (MRDT) …. For purposes of section 154 … the specified tax rate in BC is 12%. … [D]uring the effective period, the combined tax rate of 13.5% (PST at 8% plus MRDT at 3% plus Major Events MRDT at 2.5%) on supplies of short-term accommodation in Vancouver exceeds BC’s specified tax rate of 12%. ...
Article Summary
Brent F. Murray, "Incoterms 2010 Rules and Place of Delivery", Canadian GST Monitor, No. 274, July 2011, p.1. -- summary under Paragraph 142(1)(a)
In this situation, as explained in Question No. 18 from the February 24, 2000 GST Roundtable Meeting with the Canadian Bar Association (Sales & Commodity Tax Section), the CRA may determine that the place of delivery occurs in a different place, as follows: In the scenario described above, the terms are that delivery is FOB the non-resident's place of business. ...
Article Summary
Derek G. Alty, Brian M. Studniberg, "The Corporate Capital Structure: Thin Capitalization and the ‘Recharacterization' Rules in Paragraphs 247(2)(b) and (d)", Canadian Tax Journal, (2014) 62:4, 1159-1202. -- summary under Subsection 247(2)
The first circumstance arises where the economic substance of a transaction differs from its form …. ...
Article Summary
Derek G. Alty, Brian M. Studniberg, "The Corporate Capital Structure: Thin Capitalization and the ‘Recharacterization' Rules in Paragraphs 247(2)(b) and (d)", Canadian Tax Journal, (2014) 62:4, 1159-1202. -- summary under Article 9
The first circumstance arises where the economic substance of a transaction differs from its form …. ...