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ARCHIVED - Excise and GST/HST News - No. 88 (Spring 2013)

Election to not account for GST/HST on actual taxable supplies Effective for supplies made after March 21, 2013, the budget proposes to allow a participating employer of a pension plan and a pension entity of the pension plan to make a joint election to treat an actual taxable supply of property or a service by the employer to the pension entity as being made for no consideration where the employer accounts for and remits tax on the deemed supply of the property or service or on the consumption or use of inputs for the purpose of making the actual supply. ... Relief from accounting for tax on deemed taxable supplies Effective for fiscal years of an employer beginning after March 21, 2013, the budget also proposes that: A participating employer of a pension plan would be fully relieved from applying the deemed taxable supply rules in respect of the pension plan for a fiscal year where: an election with a pension entity of the pension plan to treat actual taxable supplies as being made for no consideration (discussed above) is not in effect for the employer; and the amount of the GST (including the federal part of the HST) that the employer was (or would have been, but for this measure) required to account for and remit under the deemed supply rules in respect of the pension plan in its preceding fiscal year is both less than $5,000 and less than 10% of the total net GST (including the federal part of the HST) paid by all pension entities of that pension plan in that preceding fiscal year. ... An employer that is entitled to relief under this provision would also be able to treat its actual taxable supplies as being for no consideration where the election, discussed above, is in effect. ...

Internal Audit – Trust Account Examination

During the last 2 fiscal years (2016 to 2017 and 2017 to 2018), significant changes have taken place within the Business Compliance Directorate, including: regionally centralizing workload development for trust account examinations shifting functional responsibility for the GST/HST and Air Travellers Security Charge programs to the GST/HST Registration & Filing Compliance Section implementing a new 3-tiered quality assurance program Taking into consideration the volume of money collected and the fact that the Trust Accounts Examination Program had never been audited, an internal audit to assess the existence and strength of the internal controls that support the governance of the programs was relevant and timely. 2. ... Recommendation 1 Further to the progressive evolution of the program, the Collections and Verification Branch should develop and implement file selection criteria to allow for a more holistic approach to risk assessment that takes into consideration the multiple business lines (Payroll, GST/HST, and Air Travellers Security Charge) and sources of workload (referrals, leads, and generated by Workload Development) to create a prioritized risk-based workload for the Trust Accounts Examination Program. ... In measuring the fiscal impact of the payroll files, no consideration is given to the extent of the examination officer’s work on the file or to the efforts of the Regional Workload Development Team in identifying the non-compliant taxpayers. ...

Taxpayer Relief Audit

For individual taxpayer requests, the CRA has control structures in place to ensure that TR cases are resolved with due care and consideration. ... Consideration is also given to situations where taxpayers are unable to pay due to financial hardship. ... Conclusion The CRA has control structures in place to ensure that TR requests are resolved with due care and consideration. ...

Report on Plans and Priorities 2014–15

Much of the Future-oriented Statement of Operations is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ... Yes (March 31, 2015) GHG emissions (CO2 equivalent) in fiscal year 2005-2006. 403 tonnes GHG emissions (CO2 equivalent) in current fiscal year. 318 tonnes Percentage change in GHG emissions from fiscal year 2005-2006 to the current fiscal year-21% Goal: Waste and asset management Target: Green procurement As of April 1, 2014, the CRA will continue to take action to embed environmental considerations into Crown procurement. ... Targeted performance level: Seeking to reach "Achieved" Implementation strategy element: Integrate environmental considerations into corporate policies, processes, and practices in accordance with departmental refresh cycles. ...

Regional and branch highlights

Learning and awareness: Commitment to SD appears in 100% (80) of senior manager (EX/SM) performance expectations and accountability agreements. 100% of RMT members recommended and supported development and implementation of local SD programs; SD leads identified at all responsibility centres SD Lens developed by HQ and distributed to regions in the third quarter of 2003-2004; all SD leads (15) provided with lens to help advise senior managers on integrating SD into business plans and proposals; SD appears as SMT standing agenda item at 75% of responsibility centres SD awareness presentation delivered to 95% of SOR senior managers SD considerations have been integrated into regional procurement training (WEBRO, WHMIS), new employee orientation packages, and local IT end-user training, and has appeared in employee information packages developed in support of major renovation and construction projects (Hamilton and St. ... The Materiel Management Directorate (MMD) updated the procurement certification program to include environmental considerations and green content. ... Information Technology Best practices: Used the Green Move Protocol to relocate staff to new IT campuses throughout the year Incorporated SD considerations into branch procurement of IT hardware, printers/ photocopiers (duplex-capable), and energy efficient monitors; recycled toner cartridges, diskettes, and CDs Reduced the number of printers, photocopiers, and fax machines on each floor to conserve energy and paper use (for example, the branch now has a ratio of 40 employees to 1 printer) Learning and awareness: Hosted regular lunch and learn session on various SD topics Promoted SD and wellness to employees through information provided on the branch Wellness Web site As an employees SD awareness activity, the branch collected 470 disposable cups in two days from five floors of the Fitzgerald Campus, and used the cups to make a Paper Cup Man to display in the foyer of the campus. ...

13 August 2024 GST/HST Interpretation 246538 - Determining if a limited partner of a partnership can claim an ITC

Pursuant to the recitals of the [agreement 2], the LP has engaged the Manager to carry out […]with respect to the Project in consideration of certain fees, all set out in the [agreement 2]. 17. ... Comments on agreements provided The agreements provided do not substantiate that the payment made by LP1 to [corporation 1] to reimburse [corporation 1] in respect of a Project Bonus payment [corporation 1] made to its employee was consideration in respect of a supply of a service acquired by LP1 for consumption, use or supply in the course of the activities of the LP. ... There is no evidence that the LP gave any consideration to the Project Bonus payment set out under the [agreement 4]. ...

9 July 2024 GST/HST Interpretation 247650 - Public Service Body Rebate for […][a Hospital Authority resident in a participating province in Canada]

Subsection 259(1) defines “qualifying funding” of the operator of a facility for all or part of a fiscal year of the operator to mean "a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property that are made available, or services that are rendered, at the facility during the fiscal year or part and is paid or payable by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ... Medical funding of a supplier in respect of a supply means an amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the supplier in respect of health care services for the purpose of financially assisting the supplier in making the supply or as consideration for the supply by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made. ...

ARCHIVED - Excise and GST/HST News - No. 101

The set on-call fee that is paid in respect of this on-call coverage would be consideration for this taxable supply. Additional amounts paid to compensate the medical practitioner for their intervention in patient care would generally be viewed as consideration for an exempt supply, as that intervention would generally qualify as an exempt supply of a health care service under section 5 of Part II of Schedule V. ... It should also be noted that if the consideration for the supply of the right to call upon the medical practitioner is payable or reimbursed by the government of a province, under a plan established under an act of the legislature of the province to provide for health care services for all insured persons of the province, the supply of the right may be an exempt supply of property under section 9 of Part II of Schedule V. ...

ARCHIVED - Corporations: Association and Control

(c) The dividends are calculated as a fixed amount or by reference to a fixed percentage of the fair market value of the consideration for which the shares were issued. ... (e) The shares cannot be redeemed, cancelled or acquired for more than the fair market value of the consideration for which the shares were issued plus any unpaid dividends on such shares. ... Since a share that is issued as a stock dividend is issued for no consideration, it cannot qualify as a share of a specified class because it cannot satisfy characteristic (e) above. ...

Report on Plans and Priorities 2016-17

Seeking to reach "Achieved" Integrate environmental considerations into corporate policies, processes and practices in accordance with departmental refresh cycles. ... The CRA will continue to ensure that its decision-making process includes consideration of FSDS goals and targets through the Strategic Environmental Assessment process. ... Much of the Future-oriented Statement of Operations is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ...

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