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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. ...

[T]he terms of an agreement (that is, the treatment agreed upon and reflected in an invoice) between an acupuncturist and patient establish what the acupuncturist is agreeing to provide and what the patient is expecting to receive for the consideration paid. ...

However, if neither supply is considered to be incidental to the other, then it will be necessary to allocate the consideration between the part attributable to the book and the part attributable to the other item. ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.12-- summary under Subsection 220(3.5) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.5) Finance “will consider situations where the application of late-filing penalties creates a disproportionate burden on low-income taxpayers” What are the policy considerations for s. 220(3.5) penalties arising on making late elections as permitted in the Minister’s discretion under Reg. 600 and on making them more equitable, particularly for individuals? ...

28 May 1996 Interpretation File No. 11675-1-- summary under Subsection 124(3) Summary Under Tax Topics- Excise Tax Act- Section 124- Subsection 124(3) interest but not penalty applied retroactively to announced effective date As a result of a proposed amendment to Sched V, Pt VI, s. 28, the "para-municipal" members of the correspondent would be retroactively liable for the collection of GST on supplies of electricity to the municipality for which consideration became due, or was paid without having become due, after April 23, 1996. ...