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Such an arrangement generally would not be considered to result in an abuse for purposes of s. 245(4). ...

After ruling that the compensation received by Corporation A from the bank is consideration for a single taxable supply, CRA stated: [Corporation A's] activities...are predominantly promoting and marketing the Program....Also [Corporation A] is not in the business of providing supplies of financial services or considered a financial intermediary as described under subparagraph 149(1)(a)(iii). ...

.- Q. 8 (File 932812)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Interest payable on funds borrowed to purchase newly-issued preferred shares that provide for dividends on the board's discretion and that are only entitled to a return of the subscription price on dissolution of the corporation will, in general, be considered by RC not to have been acquired for the purpose of earning income, with the result that the interest on funds borrowed to acquire the shares will only be deductible to the extent of the dividend income. ...

GST/HST Memoranda Series 2.7 Cancellation of Registration May 2005-- summary under Section 271 Summary Under Tax Topics- Excise Tax Act- Section 271 •If two or more corporations amalgamate, the successor company is a new entity and is considered to be a person separate and distinct from each of its predecessor corporations. ...

5 February 2016 Interpretation 153241-- summary under Subsection 13(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 13- Subsection 13(1) situs of medical evaluation for insurer based on its address rather than patient's CRA considered that independent medical evaluations (IMEs) supplied by non-employee doctors to insurance companies or lawyers after March 21, 2013 were not exempt health supplies. ...

3 April 2017 Interpretation 164742-- summary under Subsection 225(1) Summary Under Tax Topics- Excise Tax Act- Section 225- Subsection 225(1) litigant receiving a court award of costs plus GST/HST is not required to report such tax CRA considered that as court awards of costs (including any award on a solicitor and client scale) “do not constitute consideration for a taxable supply or a service and do not form part of the consideration paid for the lawyer’s services of the winning party,” that party is not required to account for any GST or HST in computing its net tax for the reporting period in question, even where the award of such costs included a GST or HST amount. ...

If the builder and the purchaser agree to use a stated price net of rebate for the unit, the rebate amount credited by the builder must be considered in determining the value of the consideration payable for the unit upon which the tax is payable. ...

As the Minister has the authority to accept a late-filed election, each request will be considered on a case-by-case basis. ...

An interruption between 2 legs of a journey to transfer between conveyances is not considered a stopover when the interruption is 24 hours or less or ends with the next available scheduled transportation for the next leg of the journey. ...

When determining the province in which the supply is made, a trans-border (between Canada and the United States) day trip that begins and ends in Canada, and does not include transportation by air, is not considered to have a stopover outside Canada if the scheduled stop is for less than 24 hours. ...