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2023 Ruling 2022-0955451R3 F - Post mortem pipeline

2023 Ruling 2022-0955451R3 F- Post mortem pipeline Unedited CRA Tags 84(2), 84.1, 112(3.2), 112(7), 164(6), 245(2), 248(1)- Graduated rate estate Principal Issues: (1) Whether section 84.1 applies to deem the estate to have received a dividend on the disposition of shares in a corporation to the new corporation or to reduce the PUC of the shares of the new corporation received as a consideration for the disposition of shares in the corporation; (2) Whether subsection 84(2) applies to the proposed transactions; (3) Whether subsection 245(2) applies to the proposed transactions. ...

2023 Ruling 2023-0973911R3 - Loss Consolidation Ruling

At no time during the implementation of the Proposed Transactions will the Numberco Preferred Shares be: a. the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; b. the subject of a dividend rental arrangement as defined in subsection 248(1); c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (if the Act were read without reference to paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 50. ...

2023 Ruling 2023-0986521R3 F - 104(4) and Pipeline

After the “21 year” deemed disposition, the Trust will enter into a pipeline type transaction by way of selling some of the Subject shares to another existing Canadian-controlled private corporation (Gestion 2) as consideration for notes receivable (Notes 1 to 3). ...

2000 Ruling 1999-0011563 F - PAPILLON

Gestion X, Gestion Y et Gestion Z souscriront à XXXXXXXXXX actions ordinaires de catégorie A de Nouvelle pour une considération en argent totalisant XXXXXXXXXX $. ...

2023 Ruling 2022-0954211R3 - Estate Freeze and Corporate Attribution

With respect to a dividend deemed to have been paid by Aco on a redemption, acquisition or cancellation of the Aco Pref 3 Shares to which subsection 84(2) or 84(3) applies, the terms and conditions of the Aco Pref 3 Shares do not specify an amount in accordance with the requirements in subsection 191(4); c) for greater certainty, the Proposed Transactions contained in Paragraphs 28 to 30 will form part of any series of transactions or events implemented to avoid, reduce, or defer the tax consequences, described in subsection 104(4), to the First Trust on its 21st anniversary; and d) nothing in this letter should be construed as confirmation, express or implied, that, for the purposes of any of the Rulings given above, any adjustment to the FMV of the properties transferred or the redemption amount of the shares issued as consideration, whether pursuant to a price adjustment clause or otherwise, will be effective retroactively to the time of the transfer and issuance of shares. ...

Forgiven Debts Considered Bad Debts

For purposes of the Excise Tax Act (the "ETA"), forgiven debts pursuant to an arrangement under the Companies' Creditors Arrangement Act are considered to be bad debts as opposed to reductions of consideration. ... Opco could not pay the consideration nor the GST/HST payable in respect of the supplies. ... Rationale Suppliers A, B and C filed their returns accounting for the GST/HST payable under Division II in respect of the supplies, remitted their net tax and a portion of the debt consisting of both consideration and tax owed by Opco became uncollectible. ...

10 June 2022 GST/HST Interpretation 236273 - – [Adjustments to previous returns -] […] foreign currency conversion

[INTERPRETATION REQUESTED] […][You ask if a registrant can adjust] previously filed net tax returns arising from […][foreign currency] transactions by using the day the GST/HST is payable for converting the value of the consideration for a supply into Canadian currency pursuant to section 159 of the ETA or by using another day acceptable to the Minster as described in GST/HST Memorandum 3.6, Conversion of Foreign Currency, provided the method used is applied consistently for a period of at least one year. ... [INTERPRETATION GIVEN] With respect to retroactively adjusting the method for converting the value of consideration, […], [a registrant] may request an adjustment to its previously filed net tax returns within four years after the later of the day the return was filed and the due date of the return. For a particular reporting period(s) being adjusted, [the registrant] may use the exchange rate on the day the GST/HST was payable to convert the value of the consideration for a supply into Canadian currency pursuant to section 159 or by using another day acceptable to the Minster as described in GST/HST Memorandum 3.6 provided the method used is applied consistently for a period of at least one year. […]. ...

1 March 1996 GST/HST Interpretation 11950-1[17] - Tax Treatment Applicable to Supplies of Services Made by a Person Who is Both a Freight Forwarder and a Customs Broker

With respect to expenses incurred by a supplier in the provision of services to a recipient, section 178 of the Act deems any reimbursement of these expenses to be part of the consideration for the supply of the service, except where the expenses are incurred as an agent of the recipient. ... The amount of $100 will be added to the consideration payable by the recipient. GST will be charged on the total consideration depending on the tax status of the supply. ...

13 May 1997 GST/HST Interpretation HQR0000492 - International Freight - Canada Post

Interpretation Requested Section 6 of Part VII of Schedule VI to the ETA zero-rates a supply of a freight transportation service in respect of the transportation of tangible personal property from a place in Canada to a place outside Canada where the value of the consideration for the supply is $5 or more. ... Where the total consideration for that supply is $5 or more, the supply will be zero-rated in accordance with section 6 of Part VII of Schedule VI. 2) Where non-commercial goods are transported outside Canada (international outbound freight), are invoiced to a single customer on a single invoice, and the value of the consideration for the transportation is $5 or more, the supply will be zero-rated in accordance with section 6 of Part VII of Schedule VI. ...

31 August 1998 GST/HST Interpretation HQR0000947 - Payment for Loss of Rental Income

Facts Based on the terms of the car rental agreement provided, our understanding of the relevant facts of the situation is as follows: • A renter agrees to rent a vehicle from a car rental company for a consideration which is calculated on a flat daily amount plus a specific charge based on distance driven. • The renter has the choice of accepting a loss damage waiver for an additional charge which would limit the renter's liability for vehicle damage or loss to a pre-determined amount. • If the renter decides not to purchase the loss damage waiver, the renter will be required to pay "on demand all loss or damage (however caused) to the vehicle while rented under this agreement". ... It is the Department's position that where rental agreement provides that the renter is required to compensate or re-imburse the car rental company for loss or damage caused to the vehicle while under rental or for the recovery of loss of rental revenue resulting from the damage to the vehicle, the payment made by the renter is not consideration for a taxable supply, and is not subject to GST/HST. ... Accordingly, in line with this position, it is our view that the payment made by the renter for the recovery of a loss of rental income suffered by the car rental company as described in your memo is not consideration for a taxable supply, and is hence not subject to GST/HST. ...

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