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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. ...

. … [A] number of provisions listed in Part VI of Schedule V to the Act that exempt certain supplies by public sector bodies apply to such supplies when made by a government, such as section 10 of Part VI of Schedule V to the Act, which exempts a supply made by a government of property, like a brochure, or services, such as training, where at least 90% of the brochures or training are provided for free. ...

… [A] person or partnership that operates a private school or private college is a prescribed organization and is an eligible employer for the purposes of the wage subsidy. ...

Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021-- summary under Paragraph (c) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Service- Paragraph (c) [Q.3-9] Pro rata recognition of payroll under a cost-sharing agency arrangement CRA will recognize employee cost sharing arrangements where, for example, medical professionals share support staff and only one entity has a payroll account with CRA to handle the source deductions – so that, provided the other employers open up payroll accounts with CRA, they can apply for the CEWS under s. 125.7 based on their agreed share of the payroll ...

., source deductions, and presumably also T4 reporting) – in one payroll account with CRA in its name- for employees that it pays as agent for other group companies even where the other group companies were required to open up their own payroll accounts with CRA to make CEWS claims. ...

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 …. ...

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. ...

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. ...

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. ...

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.” ...