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CRA indicated that “[o]nce GST/HST returns are filed, the registrant will receive a notice of assessment if either …a refund or rebate is owed … [or] the amount owing is more than the payment made by the registrant” – but not if the amount owing on the return as filed equals the payment made on filing. ...

As well, if the election is in effect, the following rules apply in respect of each residual input of the financial institution: the extent to which the residual input is acquired by the financial institution or is consumed or used for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) for the purpose of determining an ITC in respect of the residual input, the description of B in the formula in subsection 169(1) is deemed to be equal to the prescribed percentage for the prescribed class of financial institution … 103. To make an election under subsection 141.02(9), use Form GST118 …. ...

CRA responded: [I]n the context of section 149 … the CRA considers that "principal" refers to the person's chief or main business activity. … Some factors to be considered, but not limited to, include: the total number of supplies made and the total value of the revenue received from supplies made in each business activity; the relative value of the assets employed in each business activity; the commercial practices of the person, including the time, attention, and efforts expended by the employees, managers, or corporate officers in each business activity; and the terms of any partnership agreement if the person is a partnership, or corporate objects in the case of a corporation. ...

In situations where Holdco wholly owns a distributing corporation (Opco) and assets of Opco are spun-out to a transferee corporation (Newco) that is also owned by Holdco, the general formula for the split of the direct safe income (DSI) between Holdco and Newco is as follows: DSI on the shares of Newco: DSI of Opco prior to reorganization X net cost amount of the assets transferred to Newco / total net cost amount of the assets of Opco prior to the reorganization DSI on the shares of Opco after the reorganization: DSI of Opco prior to the reorganization X net cost amount of the assets retained by Opco / total net cost amount of the assets of Opco prior to the reorganization In a one-wing split-up butterfly wherein a portion of the assets of a corporation (DC) owned by Holdco1 and Holdco2 is spun-off to Holdco2, there could be a resulting misalignment of basis (including safe income that could be capitalized), so that Holdco1 could simply sell the shares of DC without any negative implications and Holdco2 could sell the assets it received with an increased ACB. ... For instance, CRA indicated that where there was a spin-off of ½ of the assets of Opco to Newco, entailing a transfer of ½ of the shares of Holdco’s shares of Opco to Newco, it might be necessary for less than ½ of the ACB of the shares of Holdco in Opco to be transferred to Newco. ...

Consequently … A Co has a contingent right to be paid money from Drug Co. … A Co will make a supply of these same contingent rights to Finance Co. ...

In its explanation, CRA briefly described satisfaction of the “qualifying funding" requirement in s. 259(2.1) as well as the facility accreditation requirement in s. 259(2.1)(c) (here, by the MOHLTC), and focused on the “facility supply” requirement, stating: Elim Housing … made the determination that Elim was entitled to claim the 83% PSB rebate as a facility operator operating a qualifying facility based on the presence of the following elements which indicated Elim to be making facility supplies: all of the residents had conditions that required “complex care” …; the residents were extremely dependent on care either by reason of mental or physical impairment …; residents were under the care of a physician, who was either associated with the facility or had a pre-existing relationship with the resident; a tailored care plan was created for each resident, documented and implemented: … physicians visited residents frequently (e.g., roughly on a bi-weekly basis); physicians were at, or on-call to attend, the facility at all times; physicians provided substantial medical care (e.g., addressed medical concerns, participated in medication reviews, attended interdisciplinary meetings); registered nurses were at the facility at all times, and nurses were in regular communication with physicians for prescription or advice; the facility received funding for 2.8 hours of care per resident per day (the calculation was based on scheduled staffing hours); the care provided was of a different type than ordinary assistance with activities of daily living that a more robust individual might require. ...

II, s. 9, CRA turned to the supplies made by the Corporation and stated: The […] Agreement indicates that the [Service Providers] agree to provide the services as described in […] through their profession…. ...

The qualifying revenue of an eligible employer … would include the revenue arising from the sales of new products. … [Q.6-2.3] Forgivable portion of a Canada Emergency Business Account (“CEBA”) loan not included in qualifying revenue The forgivable portion of a CEBA loan meets all the characteristics of an extraordinary item … [and] is not included in qualifying revenue. ... Likewise, qualifying revenue calculations cannot be adjusted for a recent expansion of an eligible employer's normal operations …. ... … Where an eligible employer’s normal accounting practice is to convert the inflow of cash, receivables and other consideration to Canadian currency from a foreign currency, then the eligible employer would be expected to use the Canadian currency equivalent of the amounts in the computation of qualifying revenue. ...

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Subsection 261.1(1) Summary Under Tax Topics- Excise Tax Act- Section 261.1- Subsection 261.1(1) Application to public service body Example 22 – Goods acquired in a participating province and removed to another participating province In a claim period, a non-registrant PSB purchases goods in New Brunswick for $19,000, on which it pays $2,850 in HST ($19,000 × 15%). ... The federal part of the HST paid in respect of the purchase is $950 ($2,850 × 5/15). ... The provincial part of the HST paid in respect of the purchase is $1,900 ($2,850 × 10/15). ...

Example 24 – Services acquired in participating province for partial use in another participating province In a claim period, a non-registrant PSB resident in Nova Scotia purchases advertising services in Nova Scotia for $5,000, on which it pays $750 in HST ($5,000 × 15%). ... The federal part of the HST paid in respect of the advertising services is $250 ($750 × 5/15). ... The provincial part of the HST paid in respect of the advertising services is $500 ($750 × 10/15). ...