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However, if the Canadian corporation's borrowing of funds or the giving of the guarantee can be considered to be part of the series of transactions which results in a tax benefit and may reasonably be considered to have been undertaken or arranged primarily to obtain a tax benefit, the transaction nonetheless may be subject to s. 245(2). ...

23 October 2000 Interpretation 11640-1-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 7 The Canadian operator of an internet auction site would be considered, with respect to non-resident vendors, to be arranging for, procuring or soliciting orders for supplies made by them. The payment of an annual fee by vendors for the right to list items on the auction site would be considered to be consideration for a supply to them of a right and would not be eligible for zero-rating and would be deemed by s. 142(1)(c)(i) to be a supply made in Canada. ...

("This situation may be considered abusive because the Canadian taxpayer has turned an otherwise taxable receipt of monies into a non-taxable amount.") Conversely, when a Canadian parent company requests and receive a decrease in the transfer price of sales to a non-resident subsidiary without repatriation, this is not considered abusive, because s. 15(1) would apply and offset the downward adjustment. ...

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019-- summary under Section 4.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part VI- Section 4.1 Assimilation to same place of supply of cancellation of ticket (para. 70) Example 18 A supply of a passenger transportation service from Gander, Newfoundland and Labrador to Toronto, Ontario would be considered to be made in Newfoundland and Labrador. A supply of a service of cancelling the ticket for that trip would therefore also be considered to be made in Newfoundland and Labrador and subject to the HST at a rate of 15%. ...

In other words, in order for a person (or a group of persons) to be considered to hold qualifying voting control of a corporation, 90% or more of shareholder votes in respect of all corporate matters must be held and controlled by the person (or by the group of persons) with limited exceptions. Only where a particular person (or a particular group of persons) has a high degree of both ownership and control of the corporation will the person (or the group of persons) and the corporation be considered to be closely related for GST/HST purposes. ...

" 31 March 2003-- summary under Related Business Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(1)- Related Business Although most fundraising activities are business activities, a fundraising event generally will not be considered to "recur with such regularity and frequency that it amounts to carrying on a business" (para. 12). 17. ... A business will be considered to be linked to the charity's purposes where the quality of services delivered to charitable programs are improved (e.g., hospital parking lots, and cafeterias, and museum book shops) it is an off-shoot of a charitable program (e.g., the sale by a church of recordings of its Christmas concert) it utilizes excess capacity (e.g., university rentals in the summer months) it sells products which promote the charity (e.g., products with the charity's name or logo) ...

Once s. 141.1(3)(a) so applies, it may be able to claim ITCs under s. 171(1) on property held by it at that time including expenses previously incurred by it which are considered eligible capital property for income tax purposes, given that eligible capital may be considered property for ETA purposes. ...

A stop between two legs of a journey that is 24 hours or less is not considered to be a stopover. A stop of more than 24 hours between two legs of a journey will generally be considered to be a stopover where two or more tickets or vouchers are issued for the legs of the journey. ...

"The holding of the debt outside the partnership in order to circumvent the Regulation 1100(11) restriction on CCA would be considered to result in an abuse." However, if the funds were borrowed by the partners at the date the rental property was originally acquired by the partnership, these transactions might reasonably be considered to have been undertaken primarily for non-tax purposes, e.g., the financing of the partnership in order to permit it to acquire the rental property. ...

("Time Tax Becomes Payable When Consideration Is Comprised Of A Forgivable Loan")-- summary under Subsection 152(1) Summary Under Tax Topics- Excise Tax Act- Section 152- Subsection 152(1) Respecting the situation where the consideration that is payable for a taxable management service is comprised of a forgivable loan which has a 5 year term (20% of principal amount being forgiven each year), CRA stated: Consistent with subsection 152(1) of the ETA, this consideration would be considered to become due according to the relevant written agreement between the management service provider and the client and when any invoices are issued. In the absence of any particular conditions on the loan advance or forgiveness of amounts under the loan and assuming that the entire amount of the loan advance is required to be advanced at the outset under the agreement, the consideration would generally be considered to be paid and to become due, and the tax would therefore generally be payable, at the time the loan advance is made, not at the time the loan is forgiven. ...