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More recently, CRA has substantially qualified this view by confirming that it would consider that “where a person provides property or a service to a person for no consideration but receives interest or dividend revenue from that person it is unlikely that ITCs would be available.” ...

6 March 2016- 11:29pm Lowe’s acquisition of RONA through a Nova Scotia ULC is not conditional on approval of prefs Email this Content It is proposed that RONA will be acquired for cash consideration under a Quebec Plan of Arrangement. ...

CRA stated: [T]aking into consideration the flexible tracing approach mandated… in Ludco …Amalco would be entitled to allocate the entire amount of the Assumed Debt to its assets other than the FA shares. ...

Although VAT credits were available where no current taxable supplies were being made, if the costs were being incurred for a future undertaking of making taxable supplies, that was quite different from the situation here where services were currently being supplied to the subsidiaries for no consideration. ...

Summary of Robert Demers, "Indirect Tax considerations in M&A Due Diligence," draft 2015 CTF Annual Conference paper under ETA s. 296(2.1). ...

19 May 2016- 9:09am CRA considers that a QROC distribution by a foreign affiliate to its Canadian shareholder of ECP results in ECE to the shareholder of the property’s FMV Email this Content CRA considers that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value. ...

4 September 2016- 5:40pm CRA finds that a fee for an agreement to be available to supply services was a supply of property for HST/GST purposes Email this Content CRA found that a stipend paid by a hospital to a medical specialist for agreeing to stay close to the hospital so as to be available on an on-call basis was taxable consideration for the supply of property to the hospital rather than for a supply of an exempt medical service, stating: [T]he hospital acquired a right to call upon the physician to attend the hospital during a given time period…[which] has a distinct utility to the hospital and as such…the right is a discrete supply that is separate from any health care services that may be rendered by the physician to patients of the hospital. ...

-resident actor providing such services through an LLC or S corp, the 23% withholding tax under s. 212(5.1) on the gross consideration paid can be avoided if the corporation files a Part I return for the year by its filing due date therefor and elects therein to have s. 216.1 apply. ...

CRA apparently considers that such payments (viewed by it as “franchise fees”) likely are consideration for the supply by the franchisor of “intangible personal property,” namely, “the right to operate a franchise which includes the right to use the name of the franchisor as an advertising tool and any systems made available by the franchisor to facilitate the operation of the franchise.” ...

Headquarters will generally, in turn, refer the matter to the GAAR Committee for consideration. ...