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Excise and GST/HST News- No. 97 17 November 2015-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 7 Acupuncture services – need for patient relationship Only services rendered by a practitioner of acupuncture to an individual within a practitioner-patient relationship are exempt from the GST/HST under the exemption for acupuncturists. This means that the practitioner must be a direct care provider of the patient and a relationship involving personal interaction between the practitioner and the patient must have been established for the exemption to apply. … Overlapping exemptions (e.g., dentist/acupuncturist) …[I]n some provinces a dentist may perform acupuncture services within the scope of practice for a dentist. ...

Example 2 – Goods imported into Canada In a claim period, a registrant PSB resident in New Brunswick purchases commercial goods in the United States and imports them into New Brunswick for use by the PSB exclusively (90% or more) in its commercial activities in that province. The goods are valued at $15,000 (including duties), on which the PSB pays $750 in GST ($15,000 × 5%) to the CBSA at the time of importation of the goods. ...

Example 14 – Seized property used by creditor A registrant PSB resident in Saskatchewan is not a charity to which subsection 225.1(2) (net tax calculation for charities) applies. ... The PSB is deemed to have collected GST of $1,250 ($25,000 × 5%) on the fair market value of the office equipment. ...

… As some bare trusts may be uncertain about the new requirements, the CRA is adopting an education-first approach to compliance and providing relief to bare trusts by waiving the penalty payable under subsection 162(7) of the Income Tax Act for the 2023 tax year in situations where the T3 Return and Schedule 15 are filed after the filing deadline for reasons other than gross negligence. … This proactive relief is for bare trusts only and only for the 2023 tax year. ...

“Consultation on Reforming and Modernizing Canada's Transfer Pricing Rules” 6 June 2023-- summary under Subsection 247(1.3) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(1.3) The profit allocations that were accepted in Cameco were reached based on relationships created by intra-group contractual arrangements, notwithstanding Cameco Switzerland's minimal factual substance and Cameco Canada's assumption of related risks through the provision of performance guarantees to Cameco Switzerland – so that Cameco Switzerland was left with an allocation of income that did not correspond to the value it created through its underlying economic activity. ... Similarly, it would have retained some autonomy as to the disposition of its product over time. … [T]he overall result of the application of proposed subsection [247](2.02) would be the recognition by Canco of significant additional income in line with its functional profile …. ...

IT-273R2, "Government Assistance- General Comments," para. 15-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) Timing of recceipt of benefit of tax credit ¶ 17. Federal and provincial tax credits and deductions from tax which are in the nature of inducements, or which are received as assistance for the cost of property or an expense, are included in income under paragraph 12(1)(x) in the year received unless one of the exceptions discussed in ¶ 8 applies. ...

Amounts in Cdn$/functional currency Table 1 – Overview of allocation of income, taxes and business activities by jurisdictions For electronic filing, all amounts must be stated in Canadian dollars [except that]... ... The reporting entity discloses in Table 3 – Additional Information that it is reporting in one of the qualifying currencies notwithstanding that no election has been made by the reporting entity pursuant to paragraph 261(3)(b) of the Act. ... Payments received from other CEs that are treated as dividends in the payor’s tax jurisdiction should be excluded. … “Revenues-Related Party” should be read as the aggregate amount of revenues generated from transactions between constituent entities listed in Table 2, for each relevant tax jurisdiction. ...

Revenu Quebec "Place of Supply"-- summary under Subsection 6(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(1) The place of supply determines whether the HST or the GST and QST apply....For more information on the application of the GST/HST, refer to GST/HST technical information bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province, published by the Canada Revenue Agency. ...

This is reinforced in Coopers & Lybrand Ltd. v Bank of Montreal [1993] G.S.T.C. 36…at paragraph 38: …The assessment itself, does nothing other than provide information to the debtor. ...

Whether the Court’s decision in Medallion … would apply to another situation would require examination of all the relevant facts and documents. ...