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Administrative Policy summary

GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property, August 2024 -- summary under Section 136.2

The fact that a supplier may be reimbursed for shipping costs does not affect whether a supplier is considered to have retained a common carrier or consignee on behalf of the recipient. 16. A supplier that merely contacts a common carrier or consignee to indicate that the good is ready to be transported pursuant to an arrangement that has already been established by the recipient with the carrier or consignee, or that is merely made aware of such an arrangement, is not considered to have retained the carrier or consignee on behalf of the recipient. ...
Administrative Policy summary

GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025 -- summary under Section 9

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. 30. ...
Administrative Policy summary

23 March 2017 CBA Commodity Taxes Roundtable, Q.20 -- summary under Section 2

X would be considered to be making a sale of the interest in the residential complex. … If Mr. ... X, however, is considered to be a builder in his own right (for example, at the time of entering into the agreement of purchase and sale, he did so for the primary purpose of selling the interest or the house itself), tax would be payable by the Vendor calculated on the value of consideration ($100,000) for the supply. ...
Administrative Policy summary

Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025 -- summary under Subsection 80.4(2)

Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) Identification of loan or debt 2.9 Revolving credit, such as a line of credit or a credit card, is generally considered to be in the nature of a loan or debt, so that s. 80.4(2) can apply to the revolving credit. 2.10 In the absence of a written agreement, there must be convincing evidence that a loan or debt exists. ... No netting without set-off 2.37 Generally, a deemed interest benefit under s. 80.4(2) cannot be avoided by simply netting an amount due to a shareholder with an amount due from that shareholder, given that a loan is only considered to no longer exist after its actual cancellation or extinguishment. ...
Administrative Policy summary

90 C.P.T.J. - Q.18 -- summary under Subsection 230(1)

.- Q.18-- summary under Subsection 230(1) Summary Under Tax Topics- Income Tax Act- Section 230- Subsection 230(1) Electronically-produced data generally is considered to be "records". ...
Administrative Policy summary

GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015 -- summary under Continuous Journey

Generally, the supply of a charter flight to a third-party charterer is considered to be a supply of a passenger transportation service. ... Single v. multiple supply A ferry flight is generally considered to be an input to a passenger transportation service.... ...
Administrative Policy summary

GI-120 Assignment of a Purchase and Sale Agreement for a New House or Condominium Unit 6 July 2011 -- summary under Subsection 254(4)

Generally, upon entering into an agreement for the construction and sale of a new house, the first purchaser is considered to have acquired an interest in the house. For GST/HST purposes, the assignment of the agreement to the assignee purchaser is normally considered to be a sale of the first purchaser's interest in the new house. ...
Administrative Policy summary

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019 -- summary under Section 6

Consequently, the importation of an ovum would be considered a non‑taxable importation for GST/HST purposes under section 6 of Schedule VII to the Act and therefore no longer subject to tax. Similarly, an ovum brought into a participating province from a non-participating province, or from another participating province for which the rate of the provincial part of the HST is lower, would be considered non-taxable property for GST/HST purposes under section 15 of Part I of Schedule X to the Act and therefore no longer subject to self-assessment for the provincial component of the HST, or part thereof. ...
Administrative Policy summary

Guidance on the income tax measures to support journalism CRA Webpage 23 December 2019 -- summary under Subparagraph (a)(v)

The reproduction of material produced by another organization would not be considered original news content of the organization and will factor into the determination of whether an organization is primarily engaged in the production of original news content. 2.28. Activities or publications that focus primarily on the following would not be considered the production of original news content: industry-specific publications, trade journals, travel magazines, sports or entertainment news; the rewriting, translation, reproduction or aggregation of news from external sources (including articles from news agencies, a current or previous issue of the same publication or any other publication); advertisements, listings, catalogues, directories, guides, financial reports, schedules, calendars, timetables, comic books, cartoons, puzzles, games and horoscopes; internal publications of companies, private or public bodies, or associations; and publication of content that is illegal in Canada. ...
Administrative Policy summary

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Paragraph 125.7(9)(b)

Since the prior claim period actual reduction (25%) is greater than the current claim period reduction (15%), the deeming rule applies and the reduction in revenue is considered to be 25% for claim period 5. ... Since the prior claim period actual reduction (15%) is greater than the current claim period reduction (0%), the deeming rule applies and the reduction in revenue is considered to be 15% for the claim period 6. ...

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