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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. ...

. … [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. ...