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CRA stated: We are of the view that transactions that are designed to allow a person to acquire a very substantial economic interest in a corporation (for example, perhaps by having both de facto control and a substantial equity interest in the corporation) and to benefit from the corporation's tax losses, without being subjected to the “same or similar” business restrictions in subsection 111(5), could reasonably be considered to result in an abuse having regard to the general policy of the Act against the trading of non-capital losses by unrelated corporations. ...

It is not based on the place where title to the goods transfers....If an Incoterm is used...the place where legal delivery of the goods occurs can be determined by reference to the place where delivery is considered to occur under that Incoterm. ...

CRA declined to comment on whether the supply of memberships or points was a supply of intangible personal property or real property in the absence of being provided with the relevant agreements other than to say that if the supply of points gave the recipient only the right to use real property, the supply would be considered as a supply of real property for GST/HST purposes. ...

CRA declined to comment on whether the supply of memberships or points was a supply of intangible personal property or real property in the absence of being provided with the relevant agreements other than to say that if the supply of points gave the recipient only the right to use real property, the supply would be considered as a supply of real property for GST/HST purposes. ...

CRA responded: For the purpose of determining whether the US business was "substantial" in relation to the Canadian operations in the context of [various] rulings, a number of factors were considered which included, but were not limited to: the relative amount of assets and revenues, number of employees involved in each jurisdiction, and in certain circumstances the relative amount of income and compensation expenses. … [S]ome of the more significant comparative ratios are summarized below: ...

Therefore, the Loyalty Points awarded to customers as a result of consumption of telecommunication services, on special occasions such as birthdays, or upfront based on the expectation of future consumption of telecommunication services can be viewed as a coupon upon redemption; the awarding of the points to customers is considered a taxable supply that does not attract GST/HST where there is no consideration charged to the customers for the supply. ...

18 October 89 Meeting with Quebec Accountants, Q.4 (April 90 Access Letter, ¶1166)-- summary under Subsection 191.1(1) Summary Under Tax Topics- Income Tax Act- Section 191.1- Subsection 191.1(1) Where a shareholder holds identical shares of a corporation some of which are taxable preferred shares and some of which were issued before 1987, and less than all of the shares are redeemed, the shareholder and the corporation may decide which of the shares will be considered to have been redeemed first. ...

The shares or trust units are considered to be acquired when legal ownership of the shares has been transferred and the vendor has entitlement to receive payment. ...

1993 APFF Roundtable, Q.1-- summary under Paragraph 256(1)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(a) Where a wholly-owned subsidiary ("Holdco II") of Holdco I is the sole general partner of three limited partnerships which, in turn, each hold 1/3 of the shares of Opco, Opco will be considered to be controlled by Holdco II (and therefore associated with Holdco I)- even though the general partner interest of Holdco II is not sufficient to deem a sufficient number of Opco shares to be owned by Holdco II so as to give rise to control by Holdco II- given that Holdco II appears to have de jure control of Opco. ...

22 March 1999 Headquarters Letter HQR0001233-- summary under Place of Amusement Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Place of Amusement In dealing with a question as to whether seminars put on by religious institutions would be considered to be provided at a "place of amusement", CRA stated that "a minor amount of amusement/recreation is not sufficient in order to consider a venue as a place of amusement, and indeed any amusement/recreation that is secondary to another purpose will be insufficient... ...