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ITCs under s. 186(1) for issuing shares (Stantec) Summary of Question Memorandum 8.6, para. 11, Example 3, indicates that “HoldCo” may not claim input tax credits (ITCs) under s.186(1) for legal and accounting costs incurred in connection with raising money through issuing shares, even where the issuance proceeds are used to purchase additional shares in “OpCo,” all of whose property is acquired for consumption, use or supply in widget manufacturing- on the basis that the services are acquired for consumption or use in relation to the first order supply (the share issuance) and not in relation to the shares of OpCo. However, in Stantec the Tax Court found that the s. 186(1) language implied a wide, rather than narrow, connection between the property and services acquired and the shares of the Opco, and rejected the above-noted example (published at that time in P-196R), stating: I see no support for this one step removed doctrine. ... In light of the Tax Court’s explicit rejection of the “one step removed doctrine,” does CRA intend to revise Example 3 to permit a Holdco to claim ITCs for costs incurred in connection with a share issuance of its own shares that relates directly to a purchase of additional shares in an Opco? ...

Based on the information provided, the only connection between the firm and the candidate appears to be the seeking of a future employment opportunity. ... CRA Comments a) Prospective commercial activity Generally, where a charity files an election under section 211 of the ETA that would result in the charity making taxable supplies of real property for GST/HST purposes, the charity may be eligible to voluntarily register for GST/HST purposes before the effective date of the election if paragraph 141.1(3)(a) of the ETA applies to deem something done by the charity (other than making a supply) in connection with the acquisition or establishment of a commercial activity to be done in the course of a commercial activity of the charity. ... Should large corporations always assume that they will only be considered under Category 3, or does the flexibility afforded in Memo 16-5, para. 19 for “reasonable errors” soften this connection? ...

The aircraft is delivered or made available to Lessee under the novated lease when it is physically situated outside of Canada, following which the Lessee brings the aircraft into Canada in connection with its international transportation business. ... When goods are imported, the GST is usually reported and paid in connection with a CBSA Form B3, but such forms are generally not filed for aircraft that enter Canada and are engaged in international passenger or freight transportation. ... In some cases, the CBSA has refused to accept a B3 in connection with the return of the aircraft to Canada following the novation of the lease. ...

The Queen 2008 GTC 265) has confirmed that “in the course of” should be given a wide meaning that only requires a minimal connection. ... Please provide an update regarding this new CRA program of providing advance approval for allowing discretion in connection with GST/HST registrations in the digital economy business, including: a) How many businesses have applied for advance approval to date? ... Q.18 Audit updates Please provide updates on: a) CRA audits of cannabis producers under the Excise Act, 2001, e.g., specific targeted areas or areas of non-compliance. b) CRA audits in connection with the fuel charge under Part 1 of the Greenhouse Gas Pollution Pricing Act. c) GST/HST audit issues. ...

What actions did the taxpayer take in connection with the reduction in value or the increase in cost? ...

Assuming the connection conditions are met, would you apply s. 15(2.17)? ...

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 particular, paragraph 3 provides that treaty benefits may be available to a US resident with respect to income derived from Canada, provided that the income is derived in connection with, or is incidental to, the active conduct of a trade or business (other than certain investment businesses) carried on in the US by the US resident, or a person related to the US resident, and provided that the US trade or business is substantial in relation to the activity carried on in Canada giving rise to the income. ...