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Administrative Policy summary
Excise and GST/HST News - No. 108 September 2020 -- summary under Practitioner
Therefore, supplies of osteopathy services rendered by manual osteopathic practitioners do not meet the conditions for exemption in paragraph 7(f) of Part II of Schedule V …. ...
Administrative Policy summary
GST145 Waiver of the Limitation Period for Assessment -- summary under Subsection 298(7)
Instead, use Form RC7245 … Must specify reporting periods and matters For a waiver to be valid, the end of the reporting periods and the matters for which you are waiving the application of subsection 298(1) or 298(2) must be specified. ...
Administrative Policy summary
Income Tax Mandatory Disclosure Rules Consultation: Sample Notifiable Transactions (Finance Release Webpage), 4 February 2022 -- summary under Subsection 18(19)
Income Tax Mandatory Disclosure Rules Consultation: Sample Notifiable Transactions (Finance Release Webpage), 4 February 2022-- summary under Subsection 18(19) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(19) Allocation of loss leg of straddle to vending partner A taxpayer seeks to avoid the s. 18(19) straddle-transaction rules by acquiring a partnership interest in a partnership that had an accrued loss and gain on the two legs of an FX straddle, with the closing of such acquisition being immediately preceded by the closing out by the partnership of the gain leg so that such gain is allocated to the vending partner pursuant to s. 96(1.01) – and with the loss leg realized after the acquisition and such loss allocated to the taxpayer. ...
Administrative Policy summary
GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022 -- summary under Paragraph (d)
GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022-- summary under Paragraph (d) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Builder- Paragraph (d) Treatment of assignment sales (of an agreement with a builder for a new home) under pre-s. 192.1 rules (p. 1) Under the current GST/HST rules, an assignment sale … made by an individual is generally taxable if the individual had originally entered into the agreement of purchase and sale with the builder for the primary purpose of selling their interest in the real property. ...
Administrative Policy summary
7 April 2022 CBA Roundtable, Q.1 -- summary under Subsection 165(3)
7 April 2022 CBA Roundtable, Q.1-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) an Appeals Officer can (and may) increase the reassessment under appeal CRA stated that it has the authority under ETA s. 301(3) (equivalent, although not identical, to ITA s. 165(3)) to further increase a reassessment that has been objected to (for example, if a second valuation prepared for the Appeals Officer produced an even higher valuation) – but indicated that “[a]ny upward adjustment must be approved by the Appeals Officer’s manager or the Chief of Appeals.” ...
Administrative Policy summary
S3-F3-C1 - Replacement Property -- summary under Paragraph 88(1)(e.2)
. … 1.51 While paragraphs 87(2)(l.3) and 88(1)(e.2) prevent the deferral from being lost, it may not be reasonable to conclude that the property was acquired to replace a former property. ...
Administrative Policy summary
GST/HST Memorandum 31-0, Objections and Appeals, May 2024 -- summary under Subsection 301(1.5)
In accordance with subsection 301(1.5), where a person has filed a Notice of Objection to an earlier assessment and the Minister makes a particular assessment under subsection 301(3) … [under s. 301(3)] as a result of the Notice of Objection, subsection 301(1.4) does not limit the right of the person to object to the particular assessment in respect of an issue that was part of the particular assessment and not part of the earlier assessment. ...
Administrative Policy summary
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025 -- summary under Paragraph 150(1.2)(a)
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Paragraph 150(1.2)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(a) Scope of 3-month trust 2.5 … The following trusts are considered to have been in existence for less than three months at the end of the taxation year: Trusts that ceased to exist during the particular taxation year, at a date which is less than three months after the trust was created Trusts that were created less than three months before the end of the particular taxation year. ...
Administrative Policy summary
GST/HST Memorandum 20-4 “Vocational Schools and Courses” December 2019 -- summary under Vocational School
. … 26. A sole proprietor, such as a teacher or a coach, who has a contract with a vocational school to provide a service of instruction as one of the sole proprietor’s business revenue streams is not considered a vocational school for purposes of that contract. This is because the self-employed person supplies the service to the vocational school …. ...
Administrative Policy summary
GI-197 “Out-of-Pocket Expenses” 17 December 2021 -- summary under Supply
Typical out-of-pocket expenses not generally incurred as agent that a registered supplier may charge a client include …: office supplies, if they are associated with the service being performed by the supplier for the client air travel local transportation, such as a taxi parking hotel or other accommodation per diem amounts, such as meals car rentals and gasoline an automobile allowance, where the supplier’s personal vehicle is used in the performance of the service Expenses incurred as agent When a supplier incurs an out-of-pocket expense as a client’s agent … the client is considered to be the recipient of the supply. ...