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30 December 2013 Ruling 136499-- summary under Subsection 272.1(1) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(1) distributions to GP of portion of LP set-up fees were taxable A limited partnership (the “Partnership”) engaged in lending money and received “Set-Up” fees from the borrower, which were considered by CRA to be part of the consideration for its supply of financial services. ...

29 November 2004 Interpretation 54669-- summary under Subsection 186(1) Summary Under Tax Topics- Excise Tax Act- Section 186- Subsection 186(1) Holdco required to allocate inputs but eligible for ITCs on inputs in free supplies to Opco In responding to a question on the application of s. 186(1) to inputs used by a holding company partially for making supplies of administrative services for consideration to related corporations whose debt or shares are held by it, CRA stated: [I]f a holding company acquires or imports property or a service or brings it into a participating province for consumption or use partially in relation to the shares or indebtedness of a related company and partially in relation to other activities of the holding company, the costs should be allocated pursuant to the rules in the ETA governing ITC eligibility. ...

However, where a person provides property or a service to a person for no consideration but receives interest or dividend revenue from that person it is unlikely that ITCs would be available as a result of the application of subsection 141.01(4). ...

26 February 2015 CBA Roundtable, Q. 20-- summary under Paragraph 128(1)(a) Summary Under Tax Topics- Excise Tax Act- Section 128- Subsection 128(1)- Paragraph 128(1)(a) only fully-voting shares taken into account Does the 90% test in s. 128(1)(a) only take into consideration shares that have “full voting rights under all circumstances” in both the numerator and the denominator? ...

26 February 2015 CBA Roundtable, Q. 20-- summary under Paragraph 128(1)(a) Summary Under Tax Topics- Excise Tax Act- Section 128- Subsection 128(1)- Paragraph 128(1)(a) “closely-related” is informed by policy that 90% common ownership is covered Does the 90% test in s. 128(1)(a) only take into consideration shares that have “full voting rights under all circumstances” in both the numerator and the denominator? ...

If Company C can register but not on a retroactive basis to the date of the transfer, Company C would have to pay the GST/HST on the value of the consideration of the interest in the property. ...

CRA responded: In order for the "first seller" to zero-rate the supply of the continuous transmission commodity to the "first buyer" referenced in Section 15.1 of Part V of Schedule VI, the "first buyer", in addition to the other requirements as set out in this provision, must supply evidence satisfactory to the Minister to the "first seller" that the continuous transmission commodity (CTC) has been supplied to a registrant and all or part of the consideration is property of the same class or kind delivered to the first buyer outside Canada. ...

The value of the consideration for the supply is $22,000, on which the PSB pays $2,860 in HST ($22,000 × 13%). ...

. … The PSB is required to self-assess tax at the rate of 2% on the value of the consideration for the supply of the services purchased in Ontario (2% being the difference between the 10% rate of the provincial part of the HST in Prince Edward Island and the 8% rate of the provincial part of the HST in Ontario) to the extent (expressed as a percentage) that the services are used in Prince Edward Island. ...

The reimbursement to the agent would not constitute consideration for a supply and would not be subject to GST/HST. ...