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The trust is disqualified by the existence of a power to encroach on the capital or income for the benefit of persons other than the spouse or common-law partner, prior to their death – or by a discretion of the trustee to allocate the trust’s income or capital among members of the deceased taxpayer’s family during the life of such individual. 1.27 – 1.29 Spousal discretion. ...

. … CRA can accept and process that second GST189 as it was filed in a subsequent calendar quarter and the rebate claimed is in respect of a new matter. ...

. … The CRA is currently working on streamlining the process to expedite the processing of these requests by improving internal efficiencies…. ...

Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) A public corporation and a private corporation plan to each acquire ½ of the common shares of a third corporation ("Opco"). ...

31 October 2012 TPM-14 "2010 Update of the OECD Transfer Pricing Guidelines"-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) After noting that in the 2010 version of the OECD Transfer Pricing Guidelines "there is no strict hierarchy to be applied to the selection of a transfer pricing method," CRA stated that: These changes do not firmly de-emphasize the natural hierarchy but they refocus the topic on what is truly relevant – the degree of comparability available under each of the methods and the availability and reliability of the data. ...

. … The CRA would seek to apply subsection 103(1) (and may also apply the general anti-avoidance rules…) to the allocation of income under the amended partnership agreement. ...

. … If a PSB has already claimed a PSB rebate for a claim period and subsequently discovers additional GST/HST that was paid or payable during that claim period, the PSB must adjust the previously filed rebate application to claim a PSB rebate for the additional GST/HST. ...

. … [S]ome of the more significant comparative ratios are summarized below: ...

. … In circumstances where there is a possibility of double taxation, we are prepared, in the context of a ruling request, to apply the law in a manner such that a taxpayer is not taxed twice on the same amount. ...

Therefore, the amount of ITC to be recaptured would be limited to the large business participant's interest, or $2,666.64 ($8,000 [HST Provincial Component] X 33 1/3 %). ...