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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.... ...

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. ...