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Treaty for US residents to access s. 70(6) rollover re TCP 1.63 … [F]or the rollover treatment in subsection 70(6) to apply on the transfer or distribution of property to a spouse trust, the taxpayer must be resident in Canada immediately before death. ...

GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022-- summary under Section 192.1 Summary Under Tax Topics- Excise Tax Act- Section 192.1 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. ...

. … Accordingly, no GST/HST is applicable in respect of the taxable supply made by a solo miner that performs a mining activity and receives a mining payment before February 5, 2022. ...

Thus, the issue would turn on whether there was substantial renovation of the physical space for each proposed condo unit – with CRA reiterating in this regard its longstanding position that to rise to the level of substantial renovation there would need to be a gutting (or more) of each unit at issue. ...

In finding that s. 190(1) would not apply, CRA noted that the s. 190(1) preamble requires that a person begins to hold or use real property as a residential complex – whereas here, the person (NewCo) held a single residential complex both before and after the transaction (merely expanding the size of its residential complex). ...

V, Pt. 1, s. 6 or 6.1, the portions of the upfront payments that were “attributable” to such lease intervals would be exempted – whereas the portion of the upfront payment attributable to any subsequent lease intervals where the use became taxable would be subject to GST/HST. ...

GST/HST Info Sheet GI-200 Application of the GST/HST to Credit Card Surcharges March 2023-- summary under Paragraph (i) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (i) Description of credit card surcharge What is a credit card surcharge [A] credit card surcharge is a fee that …: it is charged to the cardholder solely for the acceptance of the use of the credit card as a payment method and is not charged if another payment method is used it is imposed by the merchant who provides, to the cardholder, the property or service that is purchased with the use of the credit card [and] it is subject to the relevant payment card network rules relating to surcharging, including rules regarding the calculation and level of the fee Exemption under para. ...

Accordingly, there was no question of introducing an economic substance component – rather, it was a question of how to do so while not at the same time upending the GAAR rule and throwing out 30 years of caselaw. ...

. … Consequently, the Canada Revenue Agency will waive the application of penalties and interest for any late-filed UHT returns and for any late-paid UHT payable for the 2022 calendar year, provided the return is filed and the UHT is paid by April 30, 2024. ...

. … Ability to redeem and frequency of redemptions An investment fund provides investors with an ability to redeem with reference to net asset value (NAV). ...