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As a result, the co-venturer is still considered to have made these supplies. ...

A specific expense is net, after all applicable credits or refunds have been deducted, and is without any mark-up or profit element to the non-resident. 9....a service performed by a non-resident would not be considered beneficial to the payer if it was a duplication of services already provided by the payer's own personnel. 10....Where an amount paid or credited to a non-resident is based on an allocation or distribution of certain charges or costs among various departments, branches or subsidiary corporations (including the Canadian payer), it is important not only that the expenses themselves are reasonable but that the method or basis of allocation or distribution is appropriate to the Canadian payer and reasonable in the circumstances. ...

IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) 27 Repayments are considered to apply first to the oldest loan or debt outstanding ("first-in, first-out basis") unless the facts clearly indicate otherwise. 28....It is a question of fact whether or not a repayment of a loan is part of a series of loans or other transactions and repayments. ...

If this is the case, the Corporation as the supplier of [Product A] would be considered to have made taxable supplies of [Product A] and therefore would have an obligation to charge, collect and remit GST/HST in respect of those supplies. ...

In the case of shared rooms, the above factors and any other relevant factors should be considered in determining whether individuals are given possession of a shared room or suite. ...

GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Single v. multiple supply A ferry flight is generally considered to be an input to a passenger transportation service.... ...

Moreover… the value of the debt converted (rather than the principal amount) must be considered the amount paid to acquire the shares in determining whether the amount so paid exceeds the fair market value of the shares acquired for the purposes of paragraph 69(1)(a)….. ...

Response: It was intended that the application of s. 17.1(1)(b) would not be limited by the principle of "tracing," so that CRA would not concede that the proceeds of a debt obligation could not reasonably be considered to fund a PLOI simply because those proceeds were deposited into one account while the funds used to directly make the PLOI were withdrawn from another. ...

Although most of the mooted services here instead entailed assistance with activities of daily living, CRA noted that "there may be situations in which a service of assisting a resident with an activity that an average person would often perform on their own may be considered a therapeutic health care service. ...

After ruling that the amounts received by Organizations C from FinanceCo are consideration for a single taxable supply, CRA states: [Organizations C] activities when considered as a whole are predominantly in respect of the promotion and marketing of the Loyalty Program. ...