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I, s. 9(2) as a supply by way of sale of real property if the site had only ever been used for personal use (rather than rented out), CRA stated: For GST/HST purposes, a sub-leasehold interest in real property is considered to be real property, and an assignment of the sub-leasehold interest by a sub-leaseholder is generally considered to be a sale of real property. ...

CRA somewhat generously considered that all of these items fell within the listed s. 135 items other that the exhibition booth, which it characterized as a supply of real estate. ... These packages are all considered a single supply of promotional services, because, amongst other things, it is not possible for a sponsor to choose which benefit it wants and to only pay that price. ...

28 February 2019 CBA Roundtable, Q.19-- summary under Subsection 281.1(1) Summary Under Tax Topics- Excise Tax Act- Section 281.1- Subsection 281.1(1) CRA considered, and declined, extending its wash-trading policy to supplies made to municipalities Memorandum 16-3-1, para. 4 lists municipalities, which are eligible for 100% GST rebates, as entities that cannot be considered to have received a wash transaction. ...

An RJO can hold an interest in a partnership and it will not be considered to be carrying on a business activity if it meets all of the following conditions: the RJO’s liability as a member of a partnership is limited under any law governing the arrangement in respect of the partnership; the RJO and all non-arm’s length entities collectively hold 20% or less of the interests in the limited partnership; and the RJO deals at arm’s length with each general partner of the limited partnership. 5.15. An RJO that acquires and holds a partnership interest beyond these limits would be considered to be carrying on the business of the partnership. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Subsection 191(3) Summary Under Tax Topics- Excise Tax Act- Section 191- Subsection 191(3) supplies acquired prior to self-supply time generate ITCs even if only invoiced later Where a builder was invoiced, after the time that it self-assessed for the fair market value of a newly-constructed multiple unit residential complex (at the time of substantial completion and first tenant occupancy) for work done before that time, CRA explained the availability of an input tax credit therefor on the basis that, by virtue of s. 133: where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time). ...

… Once an eligible employer has determined that it has experienced the required reduction in revenue for a particular claim period, it is automatically considered to have experienced the required reduction in revenue for the immediately following claim period (deeming rule). As a result, the employer does not have to make this determination again for that next claim period …. … In a situation where the eligible employer, subsequently determines that it actually experienced the required reduction in revenue, without applying the deeming rule, for the second claim period- April 12 to May 9, 2020, the eligible employer will be considered to have experienced the required reduction in revenue for that third claim period because of the deeming rule that can now be applied to the third period …. ...

27 February 2020 CBA Roundtable, Q.4-- summary under Paragraph 179(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 179- Subsection 179(1)- Paragraph 179(1)(b) meaning of causing physical possession transfer in s. 179(1)(b) What factors should be considered in determining whether a registrant “causes physical possession of the particular property to be transferred” for purposes of s. 179(1)(b)? ... Generally, a registrant who has physical possession of the tangible personal property and transfers physical possession of the property would be considered to have caused physical possession of the property to have been transferred for purposes of paragraph 179(1)(b).... ...

As a result, where the real property is both situated in Canada and outside Canada, the proportion of the supply of the intangible personal property that relates to the real property that is situated in Canada is considered to be made in Canada, while the proportion of the supply of the intangible personal property that relates to the real property that is situated outside Canada is considered to be made outside Canada. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2.3) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.3) Ordinary course exception 1.28 The exception in S. 15(2.3) can apply where the debtor or borrower is a shareholder or a shareholder employee. 1.30 A lender is generally not considered to be in the ordinary business of lending money where the lender issues loans for the purpose of an occasional investment of surplus funds, to make accommodations to friends or customers, or to make advances that are intended to remain a part of the capital of a borrower. 1.33 A trade debt is considered to arise in the ordinary course of a creditor's business, where it arose from the sale of goods or services by the creditor to a debtor, and the payment terms are the same as those provided on sales to other customers of the creditor. ...

28 May 2025 IFA Roundtable, Q.3-- summary under Subsection 15(2.6); Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series In the course of discussion of a physical, then a notional cash-pooling arrangement between a Canadian company and affiliated foreign companies, CRA indicated that: the automatic cash sweeps that occur as part of a physical cash-pooling arrangement would likely be considered to form part of the series described in s. 15(2.6), which would render the s. 15(2.6) exception unavailable (so that withholding under s. 214(3)(a) would not be refunded). similarly, the anticipated frequent and ongoing movements in the account balances of participants to a notional cash-pooling arrangement would likely be considered to form part of a series of loans, repayments, and other transactions. ...