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Administrative Policy summary
27 April 2018 Ruling 185888 -- summary under Section 15
. … The addition of a medical escort along with medical equipment and supplies would not transform a commercial aircraft into an air ambulance. ...
Administrative Policy summary
27 April 2018 Ruling 185888 -- summary under Supply
V, Pt, II, s. 5, depending on who accompanied the patient – whereas if the attendants were paramedics it would not be exempted. ...
Administrative Policy summary
27 April 2018 Ruling 185888 -- summary under Section 6
After finding that the repatriation services were a single supply, CRA went on to state: [N]ursing … includes activities such as providing treatment, assessing the health care needs of […][an individual], analyzing the findings of a health assessment, and determining the appropriate service, treatment or equipment. ...
Administrative Policy summary
Excise and GST/HST News - No. 106 June 2019 -- summary under Paragraph (r.4)
Pizzitelli J applied the single supply doctrine in finding that the predominant element of what was being supplied by the dealer was an exempt supply of arranging for the insurance – and that the exclusion in (r.4) of the definition of an exempt financial services for promotional and various administrative services did not apply. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.4 -- summary under Subsection 281.1(2)
CRA responded: As indicated … Memorandum 16-5 [para. 33] VDP applicants are required to submit information for the four calendar years before the date the application is filed for applications under Category 1 or Category 2. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.6 -- summary under Subsection 281.1(2)
. … [T]the NVCC is currently responding to requests for call-backs promptly. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.12 -- summary under Agency
. … [T]here are three essential qualities that help in determining whether a person is acting as agent in making a transaction on behalf of another person. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.22 -- summary under Subparagraph 7(a)(ii)
Since s. 256.1 only referenced ss. 6.1 and 6.11, DeveloperCo was not entitled to a rebate under s. 256.1 for the HST charged to it on the development costs borne by it – notwithstanding that the transactions generated fully-taxable revenues from the sublease purchasers. ...
Administrative Policy summary
4 September 2019 Comfort Letter - Principal Residence Exemption for Trusts -- summary under Clause (c.1)(iii.1)(B)
Finance stated that it would recommend an amendment (effective for taxation years beginning after 2016) to: Allow … an inter vivos trust for the benefit of an individual who is DTC-eligible to be eligible to claim the principal residence exemption as long as certain conditions are met. ...
Administrative Policy summary
27 February 2020 Report of the Quebec Ombudsman entitled "“So that taxpayers’ rights are upheld in payment arrangement proposals with Revenu Québec” -- summary under Subsection 169(3)
The report found that it was abusive and improper for the ARQ to reassess without an adequate evidentiary foundation capable of surviving judicial scrutiny – and that, in such instances, the reassessment should be dropped. ...