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Eligible spin-offs-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) // www.cra-arc.gc.ca/tx/bsnss/tpcs/frgncrp-eng.html ">"Information for foreign corporations" 6 March 2012: Respecting the requirement in s. 86.1(2)(b) that the distribution consist only of shares, CRA states: If the shares distributed in the course of the spin-off had rights to purchase other shares attached to them, the corporation should confirm that the rights plan was established for bona fide business purposes other than to obtain a tax benefit. ...

26 February 2015 CBA Roundtable, Q.21-- summary under Qualifying Member Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Member s. 186(1) does not deem use of property in commercial activity CRA indicated that s. 186(1) applied “only for the purpose of ITC calculations” and does not have the effect of deeming the holding company to be engaged in commercial activity – so that it would generally not qualify for the purposes of making a s. 156 election with a subsidiary so as to avoid having to charge GST on management fees. ...

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Section 13 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations, No. 2- Section 13 Public service body acquiring software programming services for use in two provinces Example 7 references a PSB that is charged at the Ontario rate of 13% on software programming services acquired by it for “use” 80% at its Ontario head office and 20% at one of its offices in PEI – and goes on to note that the PSB would be required to self-assess itself for the 2% higher PEI HST rate on the 20% portion for use in PEI, before then calculating its s. 259 rebate. ...

. … The person that is eligible to claim the ITC for the tax paid or payable on the property or service is usually the recipient. ...

CRA stated: We confirm that an electronic signature produced using […] or [a] similar device is acceptable for purposes of filing a GST/HST rebate application, provided the signature and any related electronic records exhibit the characteristics of reliability, integrity, and authenticity, as discussed in GST/HST Memorandum 15.2, Computerized Records. ...

CRA ruled that the rebate is financial assistance and does not reduce the consideration for the supply of the electricity – so that input tax credits or public service body rebate claims of the recipient are not reduced by the rebate amount. ...

8 March 2018 CBA Commodity Tax Roundtable, Q.13-- summary under Paragraph 157(1)(b) Summary Under Tax Topics- Income Tax Act- Section 157- Subsection 157(1)- Paragraph 157(1)(b) wire transfers can get lost because of intermediary banks cutting off essential characters CRA observed that because “intermediary banks often have a limit on the number of characters allowed in [a wire transfer] transaction, so this can result in some essential information being cut off” thereby resulting in difficulties allocating payments from non-residents and others to the correct account – and stated that “Currently, the best way to ensure that a wire transfer is successful is to also send a fax with the account information.” ...

Association of Kinesiologists, who provided various treatments to patients, that “as kinesiology services are not listed in the Health Care Services (GST/HST) Regulations … they are not exempt from GST/HST under section 10 of Part II of Schedule V.” ...

28 February 2019 CBA Roundtable, Q.10-- summary under Subsection 220(4.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.1) Minister will consider other forms of security offered ETA s. 314(2) provides that “the Minister shall accept security, in an amount and a form satisfactory to the Minister … for payment of any amount that [has been objected to].” ...

GST/HST Memorandum 20-4 “Vocational Schools and Courses” December 2019-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply bifurcation what otherwise might be a single supply of flight training time into a taxable and exempt component CRA indicated (at para. 55) that the supply of solo and dual flight time by a flight school to would-be pilots can qualify as exempt vocational training only to the extent that such flight time does not exceed the minimum flight times set by federal regulation for the provision of licences and ratings – and that the purchase of hours in excess of this minimum is taxable. ...