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. … 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 %). ...

. … 7.18 Self-certification forms have been developed by the CRA to assist financial institutions in establishing the status of account holders under Part XVIII and Part XIX.... ...

Since CanCo and [its parent] USCo are not Interac Association Members, the Processing Services are contracted to a third party, […], an Interac Member and Acquirer. ...

Profit- Shares retention of shares' capital property character on intercorporate rollover transactions The questioner referred to the Revenue Canada position- that, in situations where a corporate taxpayer has acquired, on a section 85 "rollover," property that was non-depreciable capital property of a controlling shareholder or a "sister" corporation, it was ordinarily prepared to accept that the nature of the transferred property would not have changed solely because the taxpayer resold the property soon after the rollover – and asked whether this position was affected by the Mara Properties decision (95 D.T.C. 5168 [subsequently reversed at [1996] 2 S.C.R. 161]). ...

. … 25. Electronic image means the representation of a source document that can be used to generate an intelligible reproduction of that document, or the reproduction itself. ...

CRA considered that these provisions do not interfere with its current practice of simply assigning a GST/HST registration number to someone who should have been registered, and then assessing the person under that number for unremitted net tax – and noted that CRA could still assess that person under paragraph 296(1)(a) of the ETA for unremitted net tax in respect of reporting periods prior to that person’s effective registration date. ...