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. … ParentCo is still a separate legal entity and, as such, is a separate person with its own BN. … SubCo would no longer exist as a separate person. As a result, its BN must be cancelled, including its GST/HST program account. … ParentCo will be required to obtain its own GST/HST account number under its existing BN where it is a registrant for GST/HST purposes. … According to the Regulations, the application of section 148 is a prescribed purpose with respect to section 272 of the ETA. ... This means that ParentCo would be required to take into account SubCo’s consideration from taxable supplies over its previous four calendar quarters when determining whether it is required to register for GST/HST purposes. … Under subsection 240(2.1), ParentCo would be required to apply for GST/HST registration before the thirtieth day after the day it makes its first taxable supply in Canada. ...

RC1 Request for a Business Number and Certain Program Accounts-- summary under Subsection 240(2.1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(2.1) Different form for SLFIs Do not use this form if both of the following apply to you: • You are a selected listed financial institution (SLFI) for goods and services tax/harmonized sales tax (GST/HST) purposes or Quebec sales tax (QST) purposes, or both • You want to register for GST/HST and QST purposes or you are already registered for GST/HST purposes and want to register for QST purposes only. ... Assignment of BN to federal corporations or participating provincial corporations You must have a BN if you only want to register for program accounts. • To register for additional payroll deductions, information return, import-export, or charity program accounts, fill in another part C, E, F, or G, as applicable, of another form RC1 and attach it to this form. • You do not need to fill in Part D if you incorporated your business federally or with a province which has partnered with the Canada Revenue Agency (CRA). ... " Corporation income tax (RC)." [This link states: If you incorporate by submitting Form RC1, Request for a business number and certain program accounts, or with the province of Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Saskatchewan, Prince Edward Island, or with Innovation, Science and Economic Development Canada, you should receive a notice confirming your nine-digit BN and a summary of your CRA program accounts by mail.] ...

In this case, the following rules apply: • Because you are considered to have made a taxable sale of the real property, you can claim an ITC equal to the basic tax content of the property just before the election took effect. This means that you can now claim an ITC for all or part of the GST/HST that you paid, or that was payable, on your last acquisition of the property (for example, when you originally bought, or last self-assessed on, the property), and on any improvements you made to it, that you could not previously recover. • You have to report the tax you are considered to have collected on your deemed sale on your GST/HST return for the reporting period in which the deemed sale occurred. • You can claim an ITC for the GST/HST you are considered to have paid on your deemed purchase to the extent that you use the real property in your commercial activities. This is because the primary use rule that you would normally use to determine your ITCs for a purchase of real property does not apply … ...

In rejecting the Association’s submission that it collected its fees as Society membership dues as agent for the Society notwithstanding a statement in the Society’s by-laws that: “On behalf of the Society membership, […] [Districts, such as the Association,] shall pay to the Society an annual fee based on a per capita rate for each of its […] Members,” CRA confirmed its statements in a previous ruling letter to the Association that: [T]he bylaws of the [Society] provide no liability to the individual members to pay membership dues to [Society]. In particular, pursuant to section […] of the [Society]’s bylaws, the [District] organizations have the obligation to pay an annual fee to the [Society]. Although the amount of this fee is calculated based on the number of individual members, the individual members are not liable to pay this fee to the [Society]. … Therefore, the value of the consideration for [the Association]’s supplies of memberships is the entire amount charged by [the Association] to the individual members. ...

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed A proposed GST/HST amendment would zero-rate the supply of an ovum – which would have the effect of rendering the importation of an ovum as a non‑taxable importation. ... Respecting the application of the ovum amendment, for example, CRA indicates: [S]uppliers can stop charging GST/HST on supplies of human ova in accordance with the proposed amendment as of March 20, 2019. … [C]onsistent with its standard practice, the CRA is administering this measure on the basis of the proposed amendment [and similarly re … However, the CRA cannot pay a rebate for an amount paid in error as or on account of tax until the proposed amendment becomes law. A supplier who has charged or collected GST/HST on human ova supplied after March 19, 2019, must include that amount in the calculation of their net tax on their GST/HST return …. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 13(4.1)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(4.1)- Paragraph 13(4.1)(b) Similar business categories 1.41 …[T]wo businesses will be considered to be similar if they both fall within the same one of the following categories: merchandising- retailing and wholesaling; farming; fishing; forestry and forest products; extractive industries, including refining; financial services; communications; transportation; construction, including subcontracting; and manufacturing and processing. 1.42 … [W]here a business falls into more than one, a similar business will be one that falls into any one of these categories in which the business operates. ... As a result, if the plywood plant is sold, any business that also falls under the forestry and forest products or manufacturing and processing categories will generally be considered a similar business …. 1.43 A taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a similar business. … Similar services businesses 1.44 Service industries, such as hotels, restaurants, repairs, professional services, barber and hairdressing shops, funeral parlours, laundries, real estate agencies, tourism, and entertainment, are not included in the general business categories referred to in ¶1.41, because most of these industries are too varied and different to permit categorization. … [S]imilar business will generally be interpreted in a reasonably broad manner. ...

Also describes how a corporate shareholder which files electronically is to provide the required information, and states that a letter filed by a taxpayer with a paper return should contain: ◦ written notification that the shareholder is electing to defer tax relating to the distribution of spin-off shares from a U.S. (or other foreign) corporation, including a description of both the original and spin-off shares; ◦ the number, cost amount otherwise determined, and fair market value of the client's original shares, both immediately before the distribution and after the distribution; and ◦ the number and fair market value of the spin-off shares immediately after distribution. ...

Where, upon completion of a course, documentation is provided that does not attest to the competence of an individual to practise or perform a trade or vocation but merely states that the individual has taken and passed the course, the course will not qualify for zero-rating under section 18 …. ... Corporation Tree-NB invoices the non-resident company and not the employee. … While stand-alone industry safety courses may be beneficial, and in some cases a job requirement, on their own they would not be considered to lead to an occupation. As the course offered by Corporation Tree-NB does not lead to a diploma or certificate attesting to the competence of the individual to practice a trade or vocation, the course is not zero-rated under section 18 …. ...

. … 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. … [S]hipments of fuel oil to CanCo commenced only after the agreement for the supply was reached …. ...