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28 February 2019 CBA Roundtable, Q.16-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) CRA accepts ONEnergy, including that “either” s. 141.1(3) or 141.01(2) can be satisfied ONEnergy … held that s. 141.1(3), which provides for an input tax credit where the property or service is acquired in connection with the acquisition, establishment, disposition or termination of a commercial activity, is more specific than s. 141.01(2), so that a person will not lose the entitlement to claim an ITC solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...

The aircraft is delivered or made available to Lessee under the novated lease when it is physically situated outside of Canada, following which the Lessee brings the aircraft into Canada in connection with its international transportation business. ...

However, the CRA Guidance provides that where a holder of a pre-existing individual account opens a new account with the same financial institution, there is no need to re-document the account so long as the due diligence requirements have been or are in the process of being carried out and, where a threshold has been applied in connection with the pre-existing account, the financial institution's computerized systems are able to link the new account to the pre-existing account. ...

In such a case, there must be a direct and clear connection between the payment made to the Dealer (lump-sum or periodic) and the services provided in relation to the initial sale of the […] Shares to the Client. ...

Ontario (Revenue), 2014 ONCA 575-- summary under Clause 54(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Taxation Act 2007- Section 54- Subsection 54(2)- Clause 54(2)(b) situs of specialty debt was its place of holding In connection with a plan to minimize Alberta corporate tax, the Precision group of companies reorganized to implement a structure which, among other features, resulted in interest-bearing debts being owed to the taxpayer by a Yukon company in the form of deeds of specialty debt, which were physically transferred to the British Virgin Islands. ...

GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Qualifying Group Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Group Example 1 Where OpCo (a registrant substantially all of whose preoperty was acquired for use or supply exclusively in commercial activities) establishes NewCo, which performs activities in connection with the establishment of the commercial activity which it plans to carry out "and therefore becomes a registrant. ...

In connection with an interpretation that the Concurrent Leases would constitute an arrangement similar to a lease for purposes of s. 136(1) and the definition of "debt security" in s. 123(1), CRA stated "the form of the lease agreement should be respected where the Lessor has title to the underlying property," and that "the option to purchase granted by the Lessor does not necessarily result in a change in the characterization of the Concurrent Lease. ...

In connection with an interpretation that the Concurrent Leases would constitute an arrangement similar to a lease for purposes of s. 136(1) and the definition of "debt security" in s. 123(1), CRA stated "the form of the lease agreement should be respected where the Lessor has title to the underlying property," and that "the option to purchase granted by the Lessor does not necessarily result in a change in the characterization of the Concurrent Lease. ...

The representative stated that other expenses incurred (such as legal fees for professional services in connection with the lease, travel expenses between her residence and the Property to check up on the Property, etc.) were not claimed for income tax purposes. ...

16 March 2016 Ruling 158766-- summary under Section 15 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 15 services re TPP if they “serve a particular need…relating to the property” After ruling that “each [on-site and off-site] supply of [Service X] made by [ACo] is a service in relation to TPP that is made in the province where the TPP, to which the services relate, is situated at the time the services are performed,” CRA provided a general discussion of the relationship between s. 15 and s. 16, and stated: [W]hether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the property, taking into account the objectives of the service and the particular circumstances of each case. ...