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27 February 2020 CBA Roundtable, Q.2-- summary under Subsection 301(4) Summary Under Tax Topics- Excise Tax Act- Section 301- Subsection 301(4) s. 301(4) request granted only in exceptional circumstances Regarding its policy regarding requests under s. 301(4) for the Minister to waive reconsideration of an objection, CRA stated: On receipt of [such] a request … the case will be assigned and reviewed at the earliest opportunity. ... Headquarters Appeals may be consulted on the waiver request depending on the impact or sensitivity of the case. … If the request is not granted, the objector will receive a letter advising them of the decision and the case will proceed to be reviewed with the other GST/HST objection workload. ...

CRA found that the registrant was entitled to a full ITC on the acquisition pursuant to s. 202(2) on the basis that the personal use of the passenger vehicle by the employee was to be “considered, in the case at hand, to form part of the registrant's commercial activity by virtue of subsection 173(1)(d) … thereby making the total use of the property exclusively in commercial activity (i.e., 80% commercial activity plus 20% deemed commercial activity), the registrant.” However, the registrant “will be required to remit tax in accordance with subsection 173(1) … on the employee's taxable benefit calculated on the passenger vehicle since the exception under subparagraph (e)(iii) [now, s. 173(1)(d)(iii)] (not exclusively used in commercial activity) will not apply in the circumstance.” ...

. … We may also accept security in situations where you cannot pay your debt in full. ... Acceptable security must be liquid (easily convertible to cash), equivalent or near equivalent to cash, and realizable on demand without defense or claim from third parties. … ...

E (through E’s executor, G, also not a citizen or permanent resident) is exempted under s. 6(7)(h) for 2022 and 2023 regarding E’s ½ deemed interest because E died in the year or the prior year. F is exempted under s. 6(7)(j) in each of the years for F’s deemed ½ interest because the co-owner died in the year or prior year and E’s ownership percentage at the time of death was at least 25%. ...

. … 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. ...

Is it possible to report the GST/HST in the registrant’s GST/HST Return GST34 for the reporting period that includes the closing date – just like other taxpayers who use the property more than primarily in commercial activities- and offset the self-assessed GST by claiming appropriate ITCs on line 108 or PSB rebates on line 111 of the same Return? ... To apply the offset, the two forms must be filed together. … Therefore, if a registrant public service body’s PSB rebate claim and GST60 return are due to be filed at the same time, the registrant may offset any tax remittable when the forms are filed together. ...

(a) because they were “purposely constructed or converted to be a separate and self-contained set of private living quarters” – even though their use may be diverted to provide transient accommodation. ... Not a residential property prior to substantial completion (para. 1.30, 1.31) For purposes of both (a) and (b) of the definition, CRA considers that a property in construction does not become a residential property until “construction of the property is substantially completed (generally 90% or more) so that an individual could reasonably inhabit the property” – so that there is no reporting obligation for the property if on December 31 it has not yet become a residential property. ...

. … A reassessment may be made. This means that the objection is allowed in whole or in part, and the amount assessed is adjusted. ... The assessment may be confirmed. … An upward reassessment may be made. ...

. … In general, any eligible rebate under Division VI will be for all or part of the tax paid or payable in respect of a particular transaction or deemed supply…. CRA referred to the statement in Fanshawe College, 2006 TCC 652, at para. 58 (foll’d Ottawa Hospital, 2010 TCC 53) that “The word "matter" in section 262…relates to a transaction” – but then stated: There are instances where a particular transaction can give rise to more than one rebate. ... If the time limit for objecting has passed, the person can write in and ask for a reassessment of the rebate claim for the particular claim period. … As another example, a selected PSB filed a rebate application claiming a PSB rebate of 50% of the non-creditable tax charged in respect of a particular transaction for a particular claim period. ...

A “foreign corporation” includes not only corporations incorporated outside Canada but also Canadian-incorporated corporations which are controlled directly or indirectly by a foreign entity as per ITA s. 256 – and also Canadian-incorporated corporations which are not listed on a Canadian stock exchange and which are “controlled…in part” by a foreign national or other foreign corporation. ... There also are narrowly-cast exemptions re personal use by foreign nationals within the Ontario Immigrant Nominee Program or refugees – as well as limited rebate provisions re foreign nationals who subsequently (within four years) become Canadian citizens or permanent residents, who are full-time Ontario students for the following two years or who legally work full-time in Ontario throughout the following year. ... There are various uncertainties in the absence of draft legislation or administrative guidance including: Would sequencing partnership purchases minimize the tax – for example if a partnership with 100% Canadian partners purchases on Day 1 and on Day 2, a non-resident subscribes for a 1% partnership interest, would this limit the 15% tax to 1% of the property value? ...