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30 April 2018 GST/HST Ruling 162100 - Application of GST/HST to supplies of cannabis for medical purposes

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 10. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 22. ...

30 May 2018 GST/HST Ruling 166303 - Application of GST/HST to supplies of medical marihuana

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 4. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 8. ...

4 June 2018 GST/HST Ruling 166865 - Application of GST/HST to supplies of medical cannabis

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 10. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 22. ...

29 May 2018 GST/HST Ruling 168723 - Application of GST/HST to supplies of cannabis for medical purposes

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 10. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 22. ...

2007 Ruling 2006-0215751R3 - Cross-border butterfly

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The liabilities of the Canada Group include (i) accounts payable and other accrued expenses incurred in connection with the Canadian XXXXXXXXXX Services Business, the Canadian XXXXXXXXXX Services business and the Canadian XXXXXXXXXX Services Business; (ii) XXXXXXXXXX; and (iii) XXXXXXXXXX. 12. ...

2014 Ruling 2012-0446701R3 - Butterfly reorganization

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayers or related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the above-referenced taxpayers or a related person; (c) under objection by the above-referenced taxpayers or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The liabilities of the Canada Group included: (a) accounts payable and other accrued expenses incurred in connection with the Retained Services Business in Canada and the Canadian Transferred Services Business, and (b) XXXXXXXXXX. 14. ...

2014 Ruling 2013-0500251R3 - Butterfly Reorganization

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues raised in the Rulings Request is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT

To the best of your knowledge and that of the Taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the Taxpayer or a related person, (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Taxpayer or a related person, (iii) under objection by the Taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously considered by the Directorate in respect of the Taxpayer or a related person except in the ruling documents E 2002-013371A dated XXXXXXXXXX, 2002 and 2011-039509 dated XXXXXXXXXX, 2013. ... Immediately after the Proposed Transactions are complete, the Taxpayer shall have no employees and no property other than rights in respect of the obligations of REIT #1 in connection with the Taxpayer Debenture (if outstanding at the time of the Proposed Transactions) as referred to in 40 above. ...

2014 Ruling 2014-0528291R3 - Butterfly Reorganization

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues raised in the Rulings Request is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

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