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CRA noted that USco also had another Canadian subsidiary providing services to USco in connection with marketing and sales support activities for USco's development and expansion of its user, advertiser and software developer base in Canada, but was not asked to and did not address how this might affect the PE issue. ...

In connection with ruling that the fees paid to OTS, OES and SO were not consideration for a supply (so that they could not claim input tax credits for HST on purchases of property or services in respect of the stewardship programs), CRA stated: [T]here is nothing within the WDA that makes stewards responsible for the implementation or operation of waste diversion programs or for the waste generated as a result of their products. ...

This "half-hectare rule" follows the treatment of land in connection with the definition of "principal residence" under paragraph 54(e) of the Income Tax Act. 9. ...

7 April 2022 CBA Roundtable, Q.3-- summary under Real Property Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Real Property two annexation tests for determining whether personal property has become a fixture CRA confirmed that since appliances and common area furniture and equipment that are acquired in connection with the construction of, say, a residential complex such as an apartment building and which do not become fixtures, will be considered to have been acquired for the purpose of the intended exempt rental of the completed units, so that no input tax credits will be available. ...

Q.8 Effect on PSP rebate of charity Where a charity is entitled to the PBRH rebate in connection with the GST paid on the self-supply of a newly-constructed multiple unit residential complex would not be entitled to the GST/HST public service bodies’ rebate for the GST or the federal part of the HST payable on the self-supply that the charity may otherwise have been entitled to claim. ...

However, there must be a direct connection between the consumption or use of the property or service and the activities engaged in by the person. ...

In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...

A financial institution must also confirm the reasonableness of the self-certification based on information it obtains in connection with the opening of the account, including any documentation obtained for the AML/KYC Procedures. 9.16 It is expected that financial institutions will have account opening processes that facilitates the collection of a self-certification at the time of the account opening. ...

Dealer I and Dealer II have as account holders Investor A and Investor B, respectively, and both have Part XVIII responsibilities in connection with the financial accounts they maintain. ...

In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ...