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20 January 1997 CTF Roundtable Q. 1, 9604996 - : Article XXIX B of Canada-U.S. Treaty

The marital credit is allowed only in connection with transfers satisfying each of the following five conditions. ...

9 October 1998 APFF Roundtable Q. 1, 9M18520 - ROUND TABLE 1998 APFF

The approach adopted by the government will be reflected in the draft legislation which will be made public shortly in connection with the most recent budget proposals. ...

2000 Ruling 2000-0048083 - butterfly reorganization

You have been advised by your clients that none of the issues contained herein is: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate. ...

2001 Ruling 2001-0084793 - Butterfly

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling, as they apply specifically to such parties:- is in an earlier return;- is being considered by a tax services office or taxation centre in connection with a previously filed tax return;- is under objection;- is before the courts; or- is the subject of a previously issued ruling. ...

1999 Ruling 9902623 - BUTTERFLY REORGANIZATION

We understand that to the best of your knowledge and that of XXXXXXXXXX, none of the issues involved in this advance ruling request is being considered by a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

30 October 1992 Income Tax Severed Letter 2M0333A - Published Version of 1991 Canadian Tax Foundation

The Queen,61 the court concluded that the Income Tax Act, when read in conjunction with the Canada-US tax treaty62 and the Tax Convention Act,63 empowers the minister to issue a requirement for information sought by the US authorities in connection with their own taxation matters. 2) All requirements issued pursuant to subsection 231.2(1) are considered to be for a purpose relating to the administration or enforcement of the Act. ...

Guidance on the Reporting Rules for Digital Platform Operators

Paid or credited consideration 3.15 For Part XX purposes, consideration is compensation in any form paid or credited to a seller in connection with relevant activities. ... Active seller means a seller that either provides relevant services or sells goods during the reportable period or is paid or credited consideration in connection with relevant activities during the reportable period. Consideration means compensation in any form that is paid or credited to a seller in connection with relevant activities, the amount of which is known or reasonably knowable by the platform operator. ...

9 April 2025 GST/HST Interpretation 247209 - Mining activities in respect of cryptoassets after February 4, 2022 via mining pools

No GST/HST would be required to be collected in respect of the provision of the mining activities and no ITCs can be claimed in respect of property or services acquired, imported or brought into a participating province for consumption, use or supply in the course of, or in connection with, the provision of the mining activities. ... No GST/HST would be required to be collected, in respect of the provision of the mining activities and no ITCs can be claimed in respect of property or services acquired, imported or brought into a participating province for consumption, use or supply in the course of, or in connection with, the provision of the mining activities. ...

Mining Activities in respect of Cryptoassets

In addition, if a person at any time consumes, uses, or supplies property or a service in the course of, or in connection with, mining activities of the person, that consumption, use, or supply is deemed to be otherwise than in the course of commercial activities of the person in accordance with subsection 188.2(3). ... Amendment to the definition of commercial service The definition of commercial service in subsection 123(1) is amended, and effective as of February 5, 2022, to exclude a service in respect of goods that is acquired for consumption, use or supply in the course of, or in connection with, the performance of a mining activity (as defined in subsection 188.2(1)) in Canada. ... The supply of hosting services was acquired by USCo for consumption, use or supply in the course of, or in connection with, its performance of mining activities in Canada. ...

Tax Shelter Reporting

A tax shelter is defined as any property of which it is expected, based on statements or representations made or proposed to be made in connection with the property, that the aggregate of the losses or other amounts, calculated in any of the relevant years, which a purchaser will be entitled to deduct in taxation years ending within four years of the date of acquisition of the property will exceed the cost of the interest in the property (less prescribed benefits) to the purchaser. ... The definition of what constitutes a tax shelter depends entirely on the reasonable inferences to be drawn from representations made in connection with the property. ...

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