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(b) … If a particular supply meets the requirements of both sections 17 and 18, the supplier must make an election under both sections to ensure that the supply will not be exempt under either of these sections. … [However] sections 17 and 18 are generally mutually exclusive and would not apply to the same supply of a membership. ... (c) … It would be unwieldy to require a supplier to complete a separate form in respect of every supply. Therefore, the Minister has approved a form that will allow a supplier to make an election indefinitely, until the supplier chooses that it no longer wants the election to apply … [by] complet[ing] Section D of the relevant form. … On completion of Section D, the supplier is no longer considered to have made an election in respect of any supplies of memberships as of the effective date of the revocation. ...

The test still has a gatekeeping function – avoidance still must be one of the “main” purposes – before getting to the “misuse or abuse” analysis, but this represents a more modern approach to avoidance transaction rules, and gets around some of that analytical uncertainty in situations where there are multiple purposes, leading to an artificial exercise in picking the “winner” from among those purposes. ...

8 September 2017 Interpretation 180362-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 supply made when master sales agreement entered into S. 144 provides that “a supply of goods that have been imported … but have not been released [by the CBSA] before the goods are delivered … to the recipient of the supply, shall be deemed to be made outside Canada,” so that even if the vendor is a registrant, it is not required to charge GST/HST. ... In this regard, CRA stated: Under section 133, the supply of the goods is deemed to be made when the agreement for the supply of the goods is entered into. … The relevance of the timing of when a supply is made under section 133 to the application of section 144 is reflected in the wording of the definition of "specified supply" of goods under subsection 178.8(1) … [which] distinguishes between a supply of goods that are imported after the supply is made, and a supply of goods that have been imported in circumstances in which section 144 deems the supply to have been made outside Canada. … ...

CRA responded: a) … Paragraph (a) of the definition of “residential complex” … includes that part of a building in which one or more residential units are located. ...

. … The direct charge method attaches a specific charge to each identifiable service. The indirect charge method involves an allocation of centralized service costs to particular entities using a basis or allocation key designed to reflect the proportionate benefit received. 11. … As long as the indirect charge results in an allocation that is commensurate with the expected benefit, the OECD accepts such indirect charge methods except in cases where the services are a main business activity of the provider and are also provided to third parties, in which case the direct charge method is preferable. 12. ... [After largely repeating IC 87-2R, paras. 166-170:] Costs of auditing and fundraising for the acquisition of an interest would not be allowed unless the funds were raised on behalf of another member of the group to acquire a new company. 27 28....Sarbanes-Oxley costs…should be reviewed and if the taxpayer can demonstrate that there is a benefit to the taxpayer associated with the charge/expense, it could be allowed as a deduction. … Allocation of corporate group costs 36. … It may be preferable to implement a multiple allocation basis for intra-group services to better reflect the benefits received. … For example, time spent could be an appropriate allocation basis to allocate costs of the tax services, legal services, data processing, and the usage cost of a corporate jet, while the number of employees may be an appropriate basis on which to allocate the costs of the human resources department. … Duplicate costs 38. ...

. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. However … [t]he CRA is under no obligation to accept the value used by the general partner if it is determined to be over or under valued but it will consider the general partner’s FMV determination …. ...

Example 3 – Imported supply of a service During a claim period, a non-registrant PSB resident in Ontario is the recipient of a taxable supply of consulting services made outside Canada by a non-registrant supplier resident in the United States for $10,000. ... The PSB self-assesses the amount of $500 ($10,000 × 5%) on Form GST59, GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges. ... The PSB self-assesses the amount of $800 ($10,000 × 8%) on form GST59, GST/HST Return for Imported Taxable Supplies and Qualifying Consideration. ...

. … Partnerships that carry on business in Canada and Canadian partnerships – A partnership that carries on a business in Canada, or a Canadian partnership with Canadian or foreign operations or investments, must file a return if either of the following occur: at the end of the fiscal period, the partnership has an absolute value of revenues plus an absolute value of expenses of more than $2 million, or has more than $5 million in assets; at any time during the fiscal period: the partnership is a tiered partnership (has another partnership as a partner or is itself a partner in another partnership), or the partnership has a corporation or a trust as a partner, or the partnership invested in flow-through shares of a principal-business corporation that incurred Canadian resource expenses and renounced those expenses to the partnership, or the minister of National Revenue requests one in writing ...

GST/HST Memorandum 14-8 Closely Related Canadian Partnerships and Corporations for Purposes of Section 156 June 2023-- summary under Subsection 156(1.2) Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1.2) By virtue of a qualifying group – consisting of a holding partnership (X) holding 90% of a partnership (Y) and 90% of a corporation (Z) – each holding 1/3 of Corporation L, X and Y are closely related to L, so that Z and L are closely related under s. 156(1.2) Example 7 X is closely related to Y (also a Canadian partnership) under s. 156(1.1)(b)(i)(A), so that they form a qualifying group. by virtue of X holding substantially all of the interest in Y. ...

At the time of this election, for each class of shares referred to in 2 above: • insiders of the corporation must hold more than 90% of the issued and outstanding shares • the corporation must have: –in the case of equity shares, less than 50 shareholders, other than insiders –in any other case, less than 100 shareholders, other than insiders • except for insiders, each shareholder or group of shareholders must hold at least one block of shares having a fair market value of at least $500 Attach a list of shareholders who are insiders and their shareholdings. ...