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CRA considered that these provisions do not interfere with its current practice of simply assigning a GST/HST registration number to someone who should have been registered, and then assessing the person under that number for unremitted net tax – and noted that CRA could still assess that person under paragraph 296(1)(a) of the ETA for unremitted net tax in respect of reporting periods prior to that person’s effective registration date. ...

2012 IFA Roundtable, Q.5 [preliminary-final above]-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (d) proportionate consolidation In determining whether the shares of of a Canadian corporation (Canco 1) are taxable Canadian property, CRA will apply a proportionate value approach to any subsidiary (Canco 2) of Canco 1 whose shares are themselves taxable Canadian property, so that if Canco 2 has a NAV of $401 resulting from holding Canadian real property with a value of $1,000, mortgage debt of $999 and cash of $400, Canco 1 will be considered to hold Canadian real estate with a value of ($1,000/$1,400)*$401, or $286, for the purposes of determining whether the shares of a Canco 1 derive more than 50% of their fair market value from Canadian real estate, resource or timber properties. ...

CRA stated: [W]hen a participant in this joint venture sells his/her undivided interest in the joint venture property, and the rights and obligations attached to this interest, the recipient would be considered to have acquired all or substantially all of the assets required to carry on a business. ...

A cottage supplied more than 10% for long-term accommodations would be considered a residential complex. ...

May 2016 Alberta CPA Roundtable, Income Tax Q.9-- summary under Subsection 74.4(2) Summary Under Tax Topics- Income Tax Act- Section 74.4- Subsection 74.4(2) “one of the main purposes” in s. 74.4(2) re freeze trust with minor child acquiring common shares When asked to comment on factors taken into account in deciding if “one of the main purposes” of a transfer or loan is reasonably considered to benefit a designated person, CRA stated: In… 2001-0067725 …we stated that in a situation where a trust of which the beneficiary is a minor child of the freezor acquires common shares of the freezor’s Holdco on an estate freeze, the provisions of subsection 74.4(2) will generally apply, subject to subsection 74.4(4). ...

The performance of the duties pursuant to a power of attorneyship is not considered to be a supply made in the course of commercial activities. ...

You will be considered to be making such supplies once you start providing commercial ride-sharing services, including commercial carpool services. ...

However, if your combined total annual revenue from taxable supplies of commercial ride-sharing services and other taxable supplies exceeds $30,000 (for example, $20,000 for commercial ride-sharing services and $15,000 for other taxable supplies), you will not be considered a small supplier. ...

The definition of financial service speaks of receipt as well as payment to, and so both transactions are considered exempt supplies. ...

CRA responded: [T]he non-resident would not be considered to be carrying on business in Canada for GST/HST purposes. ...