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. … Causal allocation 46. Causal allocation directly approximates the use of a particular business input using a logical and systematic approach and an appropriate allocation base. 47. ... An input-based allocation uses a calculation based on the procurative extent of other business inputs. … 51. ... Further, other distorting factors must be excluded from the ITC calculations in a revenue‑based method …. ...

. … When the vendor does not have to charge tax A different rule applies for used goods you accept as a trade-in from a person who is not required to charge GST/HST (usually a person who is not required to register for GST/HST). ... In this case, you generally charge GST/HST on the net amount of the sale or lease, that is, the price of the goods you sell or lease minus the amount you allow for the trade-in. … [S]ee GST/HST Technical Information Bulletin B-084, Treatment of Used Goods. ...

. … If the company's responsibility is limited to providing registered or licensed nurses to the facility so that the facility may satisfy its own staffing requirements, and the nurses are subject to the control of the operator of the facility and render services under the direction of the facility in accordance with the facility's responsibility to provide care to a patient or resident of the facility, the company has made a taxable supply of personnel or human resources, and not a supply of exempt nursing services. … However, if the company is responsible for the provision of nursing services to the patients or residents of the facility and is accountable for the quality of nursing care provided, the company may have made an exempt supply of a nursing service rendered by a registered or licensed nurse to an individual, where the service is provided within a nurse-patient relationship. ...

Effecting repatriation Repatriation can be accomplished by: offsetting inter-company accounts receivable from the non-resident – It should be remembered that this method of repatriation might have an effect on other items. For example, interest charges may have to be adjusted on a going-forward basis to reflect the revised inter-company balances; the transfer of money or its equivalent to the non-resident corporation; where a Canadian parent company cannot otherwise effect repatriation within a reasonable time, the creation of a shareholders loan account – This would be effective at the date of the transfer pricing transaction and may result in the application of subsection 15(2) of the Act; or netting upward and downward transfer pricing adjustments from different non-residents if both the taxpayer and all the non-residents involved agree in writing to have the amounts offset.... ...

. … [T]he CRA considers the "particular reporting period" to be the reporting period in which the ITC or deduction first became claimable. … P149 deals with situations where a registrant makes a request to have CRA adjust a previously filed return and does not apply to returns under audit or examination. ...

. … [A] requirement that the fees related to the review and approval of a land development agreement be paid in full to the regional municipality prior to the issuance of a permit by a local municipality is not evidence, in and of itself, that the services provided by the regional municipality in connection with those fees are elements of a single supply. Further, many of the fees identified are payment for a separate supply, e.g., approval of a plan amendment or a condominium conversion. … The review by the regional municipality of the land development agreement is a separate activity from the issuance of a permit by a local municipality. ...

. … [T]he “particular reporting period” [is] the reporting period in which the ITC or deduction first became claimable. …[T]he auditor…may… request further documentation, including in the case of GST/HST rebates, copies of the actual rebate forms. … HQ has reminded auditors and examiners of the above requirement…. ...

14 October 2016 Interpretation 170549-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) Westcan test for JV, co-tenancy was JV ACo and BCo, which were co-tenants of a property in construction held through a Nominee made a s. 273 election in year X + 2 designating ACo as the operator, and describing the JV activities as being the development and construction of real property. Their co-tenancy agreement was entered into in Year X and their agency agreement with the Nominee was entered into in Year X + 2. ...

14 October 2016 Interpretation 170549-- summary under Agency Summary Under Tax Topics- General Concepts- Agency co-owners required to report pro rata portions of sale made by their agent ACo and BCo, which were co-tenants of a property in construction held through a Nominee, signed an agency agreement in which Nominee was designated as the agent of ACo and BCo and which provided that the Nominee was the authorized agent and representative of ACo and BCo including for the claiming of input tax credits – and the Nominee made such claims prior to the end of the period of administrative tolerance expressed in GST/HST Notice 284. In rejecting this approach, CRA stated: [I]t is the principal who is entitled to claim any input tax credits on the supplies acquired by the agent on behalf of the principal. … The statement in the agency agreement stating that the Nominee will claim ITCs on inputs purchased in its capacity as agent does not extinguish ACo and BCo’s potential right to claim the ITCs under the ETA, nor does it result in the Nominee being entitled to claim ITCs. ...

CRA responded: [U]nder subsection 175(1) … Great Law Firm LLP would be deemed to have paid, at the time the reimbursement is paid to the partner, tax in respect of the supply of the MacBook Pro equal to the total amount of tax reimbursed. ... [T]he comments provided [above] would also apply to a reimbursement made … to its employee. ...