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However, as a result of making the joint venture election, Company C will not include consideration from taxable supplies deemed to have been supplied by Company A on its behalf in the course of the joint venture activities when determining if it has exceeded the small supplier threshold under section 148 of the ETA unless Company A is an associate. ...

Given the complexity of transfer pricing issues, applications relating to transfer pricing matters will be referred to the Transfer Pricing Review Committee for their consideration under subsection 220(3.1) ...

The CRA considers top‑ups or the addition of funds to a qualifying meal plan to be additional consideration for the same supply. ...

When a corporation realizes the accrued gain, on a property that it had acquired on a rollover basis in consideration for preferred shares, on disposing of that property, that gain is now considered to contribute to the gain on those preferred shares, so that such gain is to be included in the safe income of the preferred shares. ...

Furthermore, in these circumstances, where any amounts are deducted by the pool operator from the payment made to the person, the consideration for the person's supply to the pool operator would be the payment less the deducted amount unless there is clear indication under the arrangements between the parties that the reduction is in respect of a supply made by the pool operator to the person. ...

From the fees paid to it, the organization keeps a 5% commission for the administrative services it provides and pays the remaining amount to the child care provider as consideration for the child care services that the organization acquires. ...

Common characteristics of supplies that are not exempt under paragraph 9(a) of Part III of Schedule V include: supplies where the tutor has negligible interaction with the student because the tutoring method is based on self-learning exercises or activities (for example, games) that strengthen a variety of cognitive skills supplies where a program of tutoring provides a series of levels of attainment that every student must complete without consideration of the specific needs of the student in respect of any provincially recognized course offered by a school authority or a curriculum designated by a school authority [CRA then provided an example of a private corporation (“Corporation A”) providing a course that involved children working through a progression of non-customized math workbooks at their own pace as not qualifying given that there was little assistance from the instructor and there was “no evidence of a relationship between the supply being made by Corporation A and a course approved for credit by, or that follows a curriculum designated by, a school authority.”] ...

are taken into consideration (and given appropriate weight) in the GAAR analysis, notwithstanding that a misuse of specific provisions of the Act cannot be identified” (p. 19). including an interpretative rule which, in contrast to Alta Energy, would shift the balance more to fairness to the tax system as a whole and de-emphasize certainty and predictability, and also address application issues, e.g., providing (again contrary to Alta Energy) that GAAR applies to foreseen as well as unforeseen tax planning (pp. 19-20). reversing the Canada Trustco burden on the Crown, e.g., presuming “that abusive tax avoidance has occurred unless the taxpayer can establish to an appropriate standard that the provision or provisions being used to provide the tax benefit were used in the manner that Parliament intended them to be used” – although perhaps this burden shift would only occur where the transactions lacked economic substance (pp. 20-21). ...

For example, we would be prepared to allow a deduction in computing the income of a partnership for fees paid to a partner if the fees are paid in consideration for services provided to the partnership by the partner acting other than in his or her capacity as a partner (i.e., the services are not related to the ownership of the partnership interest). ...

. … [W]hen a partnership is recognized for income tax purposes, it will be treated as one for GST/HST purposes, and so the income tax considerations are relevant for GST/HST purposes as well. ...