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GST/HST Interpretation
14 December 2012 GST/HST Interpretation 126545 - Place of supply of services
As indicated in GST/HST Technical Information Bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province (available on the CRA web site at http://www.cra-arc.gc.ca/E/pub/gm/b-103/b-103-e.pdf), whether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the TPP taking into account the objective of the service and the particular circumstances of each case. There are several guidelines that are used to determine whether there is a direct connection between a service and TPP. ... If something else comes between the service and the TPP, the connection will not be considered to be direct. ...
Excise Interpretation
25 April 2006 Excise Interpretation 78001 - Partial Exemption of Excise Tax for XXXXX
We conclude the legislative phrases should be applied in the widest possible context, subject to there existing a causal connection between the thing being seized and the contravention. ... Somewhat less information is available on the phrase "by means of", however in a criminal case heard by the Quebec Court of Appeal, it stated that, with reference to section 68 of the Criminal Code, the phrase "by means of" necessarily implies a causal connection between the death and the alleged unlawful act. ... (emphasis added) We conclude that where the seizing officer determines, or "reasonably believes", that there is a connection between a 'thing' and a contravention of the Act, the 'thing' is subject to seizure pursuant to the provisions of paragraph 260(2)(f). ...
GST/HST Interpretation
14 February 1996 GST/HST Interpretation 11650-1[5] - Eligible Capital Property and Capital Property
Paragraph 4 of Interpretation Bulletin IT-386R indicates that there is a "mirror-image test" to determine whether an amount which a taxpayer has received in connection with a business as a result of the disposition of property, is proceeds from the disposition of eligible capital property. In effect, a taxpayer disposing of property in connection with a business "looks in the mirror" to see whether, if the taxpayer were instead purchasing the property, its cost would qualify as an eligible capital expenditure of the taxpayer for the same business. ... Therefore, it is our view that the definition of capital property in subsection 123(1) of the ETA also does not include eligible capital property, because of the close connection between the Income Tax Act definition of capital property and the definition in subsection 123(1) of the ETA. ...
GST/HST Interpretation
1996 GST/HST Interpretation 11715-1[2] - Clarification as to Certain Parts of a GST Application Ruling Issued by the Department on Behalf of
In this regard, we have enclosed herewith for your perusal a revised draft of the actual entries that will be used by XXXXX in connection with the accelerated payments program and would ask you to revise the GST Application Ruling accordingly; 4. ... You will note from your review of the enclosed revised accounting entries to be used by XXXXX in connection with the accelerated payments program that the entries now reflect a GST included amount. Would you please confirm that the accounting entries now proposed by XXXXX in connection with the accelerated payment program will not affect the ruling given in the GST Application Ruling dated December 5, 1995. ...
Archived CRA website
ARCHIVED - Eligible Capital Amounts
Examples of such transactions are the sale of a franchise or licence for an unlimited period, the sale of goodwill in connection with a business, the outright sale of a process and the sale of certain rights. ... Subparagraph 14(5)(a)(iv) has a "mirror image test" to determine whether an amount which a taxpayer has received or may become entitled to receive in connection with a business as a result of a disposition of property, is proceeds from the disposition of EC property resulting in an EC amount. ... In other words, a taxpayer disposing of property in connection with a business looks in the mirror to see whether, if the taxpayer were instead purchasing the property, its cost would qualify as an EC expenditure of the taxpayer for the same business. ...
Current CRA website
Consideration and retail value
On this page How to determine the taxable amount for the sale of a luxury item What to include What not to include Example of luxury tax calculation How to determine the taxable amount in other circumstances What is fair market value (FMV) Example of luxury tax calculation How to determine the taxable amount for the sale of a luxury item If you are a vendor that sells luxury items, the taxable amount is the value of consideration in connection with the sale of the luxury item. The value of consideration includes: the price of the luxury item being sold the price of any improvements (that is, goods that are installed on the luxury item or physically performed services that modify the luxury item) that are made in connection with the sale of the luxury item the price of any incidental goods and services that are supplied with the luxury item being sold any fees that relate to the sale of the luxury item any payable federal and provincial levies other than the GST/HST and the provincial sales tax in British Columbia, Saskatchewan, Manitoba and Quebec Where applicable, you must include all of the above in calculating the luxury tax on the sale of a luxury item. ... The dealership charges the purchaser for various improvements, incidentals, fees and levies in connection with the sale of the subject vehicle. ...
Old website (cra-arc.gc.ca)
Guidance on enhanced financial accounts information reporting
The same applies in connection with any client trust account held by a lawyer in trust for a single client in connection with legal services if the above-referenced conditions are satisfied and the lawyer’s actions in connection with the opening, use and management of the account are regulated by a law society in Canada. ... TIN is a mandatory reporting element in connection with any new account that is a U.S. reportable account. ... However, there is a phase-in period in connection with preexisting accounts. ...
Archived CRA website
ARCHIVED - Meaning of Eligible Capital Expenditure
The CRA considers that incorporation expenses and similar expenses incurred in the setting up of a new corporation or in connection with an amalgamation of two or more corporations, as well as expenses incurred in connection with the reorganization of the affairs of a corporation (including the costs of supplementary letters patent), are "eligible capital expenditures" if they meet the requirements of that definition in subsection 14(5) as explained in ¶ 2. ... If damages were paid or incurred in connection with the acquisition of an eligible capital property, the cost of the damages would be added to the eligible capital expenditure pertaining to that property. ... Expenses incurred in connection with the issue of shares of the capital stock of a corporation are discussed in ¶ 18. ...
Scraped CRA Website
ARCHIVED - Meaning of Eligible Capital Expenditure
The CRA considers that incorporation expenses and similar expenses incurred in the setting up of a new corporation or in connection with an amalgamation of two or more corporations, as well as expenses incurred in connection with the reorganization of the affairs of a corporation (including the costs of supplementary letters patent), are "eligible capital expenditures" if they meet the requirements of that definition in subsection 14(5) as explained in ¶ 2. ... If damages were paid or incurred in connection with the acquisition of an eligible capital property, the cost of the damages would be added to the eligible capital expenditure pertaining to that property. ... Expenses incurred in connection with the issue of shares of the capital stock of a corporation are discussed in ¶ 18. ...
Archived CRA website
ARCHIVED - Meaning of Eligible Capital Expenditure
The CRA considers that incorporation expenses and similar expenses incurred in the setting up of a new corporation or in connection with an amalgamation of two or more corporations, as well as expenses incurred in connection with the reorganization of the affairs of a corporation (including the costs of supplementary letters patent), are "eligible capital expenditures" if they meet the requirements of that definition in subsection 14(5) as explained in ¶ 2. ... If damages were paid or incurred in connection with the acquisition of an eligible capital property, the cost of the damages would be added to the eligible capital expenditure pertaining to that property. ... Expenses incurred in connection with the issue of shares of the capital stock of a corporation are discussed in ¶ 18. ...