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29 September 2020 GST/HST Ruling 175147- Application of the GST/HST to supplies of services made by a determined municipality to a regional municipality-- summary under Subparagraph 20(c)(i) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 20- Paragraph 20(c)- Subparagraph 20(c)(i) agreement to provide dedicated permit staff in consideration for their funding was taxable A registered charity (the “Authority”) which was a conservation authority established under the Ontario Conservation Authorities Act and that was responsible for monitoring watercourses for flood control purposes, had been determined to be a municipality under para. ... In finding that such funding was consideration for a taxable supply, CRA stated: The additional funding paid by the Region to the Authority under the Agreement is not consideration for a supply of technical input and advice or the processing of Regional permit applications. Rather, it is consideration for a supply of a service of ensuring there is a dedicated staff team to exclusively address the needs of the Region within agreed upon service delivery standards. ...

31 July 2023 GST/HST Interpretation 217772- Complimentary gift cards-- summary under Section 181.2 Summary Under Tax Topics- Excise Tax Act- Section 181.2 bifurcation of a gift card between the complimentary coupon portion and the purchased gift certificate portion A supplier issues gift cards with stipulated monetary values to purchasing customers, which they can use at its stores or at its e-commerce portal, However, to promote products or as a customer service gesture, the supplier also issues “complimentary gift cards” whose “complimentary value,” when applied by the customer, is treated by it as consideration for the goods or services supplied. ... CRA went on to note that any top-up value added to the gift card would generally be considered the issuance or sale of a gift certificate for consideration and, when redeemed for a supply of property or services, would be deemed to be applied as money as described in s. 181.2. CRA further stated: Gift cards issued in circumstances when an item is returned without a receipt would generally be considered to be issued for consideration; the value of the returned item being the consideration pursuant to paragraph 153(1)(b). ...

Regarding s. 131(1)(c), CRA stated: [S]ubparagraph 131(1)(c)(i) generally provides that where an amount is deducted from the segregated fund, and that amount is in respect of a supply of property or a service that the fund is considered to have acquired from the insurer, that supply is deemed to be a taxable supply and the amount deducted is deemed to be consideration for that supply. Subparagraph 131(1)(c)(ii) generally provides that if the amount deducted from the fund is not in respect of property or a service considered to have been acquired from the insurer or another person, the insurer is deemed to have made, and the fund to have received, a taxable supply and the amount deducted is deemed to be consideration for that supply. ... As such, in many cases, where an amount is deducted from a segregated fund, the amount will be deemed to be consideration paid by the segregated fund to the insurer for a taxable supply made to it by the insurer. ...