Search - considered

Regarding a future publication, we will confirm the position that a joint venture at law is considered to be a joint venture for purposes of the joint venture election under section 273 in a planned publication. ...

In response to Q.9 at the 2015 Roundtable, CRA indicated that, if the corporation sent to CRA, in the same envelope, a return declaring and remitting the GST under s. 191(3), and rebate claims under ss. 257 and 256.2(3) (resulting in a net refund position), s. 296(2.1) would not apply and s. 228(6) would apply, with the result that the tax would not be considered to have been paid until the filing of the return so that a s. 280.1 penalty and s. 280(1) interest would apply. ...

We note that the end result of the FCA decision is generally consistent with the CRA’s position … B-103 … regarding the application of the place of supply rules in section 142 to services in relation to real property, pursuant to which only the proportion of the service that relates to the real property that is situated in Canada is considered to be made in Canada and subject to GST/HST. ...

8 March 2018 CBA Roundtable, Q.23-- summary under Section 1 Summary Under Tax Topics- Excise Tax Act- Regulations- Deduction for Provincial Rebate (GST/HST) Regulations- Schedule 1- Section 1 provincial rebate (which is unrestricted by ETA s. 259.1) requires a pre-existing printed book Where there is a recording of a spoken reading of a book that was published electronically, such as a book published only on Kindle, with no printed version, will there be considered to be an audio recording of a “printed book? ...

8 March 2018 CBA Roundtable, Q.23-- summary under Printed Book Summary Under Tax Topics- Excise Tax Act- Section 259.1- Subsection 259.1(1)- Printed Book purely audio book ineligible Where there is a recording of a spoken reading of a book that was published electronically, such as a book published only on Kindle, with no printed version, will there be considered to be an audio recording of a “printed book? ...

These restrictions will be considered during assessment. … Similarly, please consider the due diligence issue where a tax professional has been engaged to prepare a return for a person for whom no one is authorized to sign a T183. ...

We also understand that the plan is being considered in connection with the foundation's divestment obligation for excess corporate holdings. ...

The comfort letter provides an exception from the tracking interest rules if it cannot reasonably be considered that one of the purposes for the creation or issuance of a tracking interest in an umbrella corporation or for the acquisition of the interest by a taxpayer is to avoid the corporation being a CFA for the year. ...

A supply of real property under an emphyteutic lease is considered a supply of real property by way of lease, licence or similar arrangement for GST purposes. ...

These packages are all considered a single supply of promotional services, because, amongst other things, it is not possible for a sponsor to choose which benefit it wants and to only pay that price. ...