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24 July 2003 GST/HST Ruling 41660 - Services in Respect of Real Property

Copies of invoices and/or proposal agreements in connection with the following hotel locations were provided: 1. ... The Appraisal Report was prepared for XXXXX in connection with financing of the existing and proposed subject properties, and is dated XXXXX. ... Ruling Requested Whether the services provided by XXXXX in connection with the XXXXX XXXXX XXXXX are taxable supplies under the ETA. ...

ARCHIVED - Damages, Settlements and Similar Payments

If damages are incurred in connection with the acquisition of an asset for which capital cost allowance may be claimed, the cost of the damages is included in the capital cost of that asset (or the CCA class to which the asset belongs). ... If damages are incurred in connection with the acquisition or production of inventory, the cost of the damages is included in the cost of inventory. If damages are incurred in connection with the disposition of a capital property, the cost of the damages is taken into account under subsection 40(1) for the purposes of calculating any gain or loss on that disposition. ...

Chapter History S1-F2-C1, Qualifying Student and the Education and Textbook Tax Credits

However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... These references are made in connection with the certification of an educational institution in Canada which provides courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person’s skills in, an occupation. ... Pursuant to this amendment, programs taken by students in connection with, or as part of, their duties of an office or employment are not excluded from the definition of a qualifying educational program for 2004 and subsequent tax years. ...

Platform-based short-term accommodation

The accommodation platform operator is required to charge and collect HST at 13% on any booking or administration fee it charged to the family member from British Columbia in connection with the supply of the short-term accommodation because the property is situated in Ontario. ... The accommodation platform operator is required to charge and collect GST at 5% on any booking or administration fee it charged to the family member from Ontario in connection with the supply of the short-term accommodation because the property is situated in British Columbia. ... The accommodation platform operator is required to charge and collect HST at 15% on any booking or administration fee it charged to the family member from Ontario in connection with the supply of the short-term accommodation because the property is situated in Nova Scotia. ...

2006 Ruling 2006-0181061R3 - Butterfly Distribution - XXXXXXXXXX

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request: (i) in an earlier return of the taxpayer or any related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return by the taxpayer or any related person; (iii) under objection by the taxpayers or any 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. ...

2005 Ruling 2004-0106481R3 - Employee benefit plan-Shares

To the best of your knowledge, none of the issues involved in this Ruling are: (i) in an earlier tax return of the Corporation, a Participant or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, a Participant or any person related to the Corporation or a Participant; (iii) under objection by the Corporation, a Participant or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation, a Participant or any person related to the Corporation or a Participant. ...

2013 Ruling 2012-0449611R3 - single-wing butterfly reorganization

To the best of your knowledge, and that of the above-referenced taxpayer involved, none of the issues involved in this ruling request is (i) in an earlier return of the above-referenced 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 above-referenced taxpayer or a related person; (iii) under objection by the above-referenced 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. ...

2013 Ruling 2012-0435221R3 - CCPC SAR Plan

We understand that, to the best of your knowledge and that of the above-referenced Company, none of the issues involved in the ruling request is: (i) in an earlier return of the Company 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 Company or a related person; (iii) under objection by the Company or a related person; (iv) before the courts; nor, (v) the subject of a ruling previously issued by the Directorate, except with respect to Ruling 2006-0201541R3 on the Current Plan. ...

2014 Ruling 2013-0505431R3 - XXXXXXXXXX

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request is: (a) in an earlier income tax return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed income tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving the taxpayer or a related person. ...

2011 Ruling 2010-0367251R3 - Loss Consolidation

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (i) dealt with in an earlier return of any of the above-referenced taxpayers, or a related person, (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of any of the above-referenced taxpayers or a related person, (iii) under objection or appeal by any of the above-referenced taxpayers, 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. ...

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