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. …. The TCC determined that Zomaron delivered to the acquirer/processor fully negotiated merchants requiring card payment processing services. … The TCC determined the predominant element in respect of this single supply to be “arranging for” the card payment processing services offered by the acquirer/processor to the merchants and that this “arranging for” activity was a financial service. … Although a supplier may be registered as an ISO/MSP within the Visa/Mastercard networks, the supplier may not always perform the very same services and have the very same obligations and autonomy as another ISO/MSP. … The CRA will only apply the Zomaron decision to supplies made by an ISO/MSP if the same fact situation exists. ...

. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

. … Copper IUDs have a plastic frame that is wound around with copper wire or has copper sleeves. … [H]ormonal IUDs available in Canada contain the drug levonorgestrel which is on the list established under subsection 29.1(1) of the Food and Drugs Act and require a prescription from a physician to be purchased. … Therefore, the supply of hormonal IUDs is zero-rated pursuant to paragraph 2(b) of Part I of Schedule VI…. ...

. … No GST/HST collectible by CMHC on forgivable loans There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … ...

. … (e) The later accounting of the transactions by all parties is as if the election was made … 57. A request will not be accepted in the following cases: (a) It is reasonable to conclude that the taxpayer made the request for retroactive tax planning purposes. … (c) It is reasonable to conclude that the taxpayer had to make the request because he or she was negligent or careless to comply with the law ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

GST60 GST/HST Return for Purchase of Real Property or Carbon Emission Allowances-- summary under Paragraph 228(4)(b) Summary Under Tax Topics- Excise Tax Act- Section 228- Subsection 228(4)- Paragraph 228(4)(b) Use this return to report and pay the goods and services tax/harmonized sales tax (GST/HST) when you purchase taxable real property (for example, land or a building) or you purchase taxable supplies of emission allowances (see page 3 for definition) that are made in Canada, and you are in any of the following situations: • You are registered for the GST/HST and the use or supply of the real property or emission allowances in your commercial activities will be 50% or less. • You are not registered for the GST/HST and you purchased the real property from a person who is not resident in Canada, or from a person who is considered to be resident only for activities carried on through the person's permanent establishment in Canada. • You are not registered for the GST/HST and you purchased taxable supplies of emission allowances that are made in Canada ...

Calculation of Corporation X's qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Corporation Y: $100 x $400 (QR attributable to Corporation Y)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,000(Corporation Y QR for current reference period)/$1,500 (Corporation Y QR for prior reference period) = 19 QR calculation in relation to Corporation Z: $100 x $1,000 (QR attributable to Corporation Z)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,300(Corporation Z's QR for current reference period)/$2,000 (Corporation Z's QR for prior reference period) = 46 The weighted average qualifying revenue for Corporation X for the current reference period is $65 ($19+$46). ... Calculation of Canco’s qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Forco: $100 x $900 (QR attributable to Forco)/$900 (Canco total QR from non-arm’s-length persons or partnerships) x $1,500 (Forco QR for current reference period)/$2,000 (Forco QR for prior reference period) = 75 Since the prior reference period’s qualifying revenue is deemed to be $100, Canco has experienced the required reduction in revenue of at least 15% for the claim period. ... Meaning of “substantially all” Generally, the phrase “all or substantially all” means at least 90%. … However, the “all or substantially all” test could, depending on the circumstances and context, be satisfied even if the 90% level is not strictly achieved. ­­­­­­­­­­­­­­­­ ...

. … a location may not be a RPE for an individual if, for example, the individual works at that particular location only once during the year or perhaps for only a few days in the year. … The CRA’s general position is that travel between an employee’s home and their employer’s business location is personal, even when the employee has a home office that is a regular place of employment. … CRA does not have a list of common factors used to determine if a work location is an RPE. … [F]or a location to be considered a special work site…: 1. ...