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. … [A] requirement that the fees related to the review and approval of a land development agreement be paid in full to the regional municipality prior to the issuance of a permit by a local municipality is not evidence, in and of itself, that the services provided by the regional municipality in connection with those fees are elements of a single supply. ...

In connection with ruling that the assignment is a financial supply under (d) of financial service and the fee part of the (exempt) consideration therefor, CRA stated: [E]ach… Contract…[is] a “debt security”… as each one represents a right to be paid money. ...

In connection with ruling that the assignment was an exempt supply under para. ...

3 November 2000 Ruling 32023-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 2 manager receives share of revenues of government-funded nursing home as taxable manger rather than as operator The manager and a registered charity form a joint venture with respect to an interim care nursing home (fully funded by the province) of the charity under which the charity will contribute the nursing home to the joint venture and the manager will operate the home and in connection therewith incur expenses for which it will be reimbursed by the joint venture. ...

We also understand that the plan is being considered in connection with the foundation's divestment obligation for excess corporate holdings. ...

Per … Copthorne …: ``… The fact the language of s. 248(10) allows either prospective or retrospective connection of a related transaction to a common law series and that such an interpretation accords with the Parliamentary purpose, impels me to conclude that this interpretation should be preferred to the interpretation advanced by Copthorne…`` The text and content of s. 248(10) have left open when the contemplation of the series must take place as nothing in the text specifies when the related transaction must be completed in relation to the series. ...

On the other hand, where the invention belongs to the employee, any amount he receives from his employer in connection with the invention will be treated in the following manner: (a) Where he is in the business of making inventions, the amount he receives for the sale of his rights in the invention will be taxable as income from a business; (b) Where he is not in the business of inventing, the sale of his rights in the invention to his employer will be considered a disposition of capital property subject to capital gains tax in the normal way. ...

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024-- summary under Paragraph 402(4)(j) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(4)- Paragraph 402(4)(j) Revenue from operating leases allocated based on reasonable knowledge 2.52 [W]here the land is not used in connection with the corporation’s principal business operations, subsection 402(5) of the Regulations excludes the rental revenue from property from the corporation’s gross revenue. 2.53 Gross revenue of a corporation from non-financial leases (generally, these are operating leases) should be allocated in the following manner: Gross revenue should be attributed to the permanent establishment in the province in which the leased property is being used, where the corporation has reasonable knowledge of such information. ...

If the contracting address of the recipient is not obtained, the address most closely connected with the supply would be the address of the recipient that the supplier has the most contact with and that the supplier mostly uses in connection with the supply. ...

. … If the contracting address of the recipient is not obtained, the business address of the recipient that is most closely connected with the supply would be the obtained business address of the recipient in Canada that the supplier has the most contact with and that the supplier mostly uses in connection with that supply.... ...