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Partly, on this basis, CRA considered that the relevant self-supply rule was that in s. 19(1) applicable to the substantial renovation (or construction) of a residential condominium unit rather than that applicable under s. 191(3) to the substantial renovation (or construction) of a multiple unit residential complex. ...

Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023-- summary under Residential Property Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Residential Property Focus on purpose of construction (para. 1.25) Commercial cottages, cabins and chalets situated on one lot are not considered to be residential properties- they “were purposely constructed or converted to be something other than a residence.” ...

We considered adding “avoidance of foreign tax” to the test, but ultimately concluded that adjusting the avoidance transaction test to “one of the main purposes” would ensure a better balance. ...

CRA responded: Where a building (or other structure) is being erected by or for a taxpayer on land owned by the taxpayer, they are considered to have acquired a building (or other structure), at any particular time, to the extent of: the construction costs incurred by the taxpayer to that time, including the cost to the taxpayer of materials that have been put in place, but not including holdbacks that constitute a conditional liability (for example, a holdback which requires that the work be approved by the taxpayer’s architect or engineer before payment), or progress billings received by the taxpayer to that time, net of any holdbacks that constitute a conditional liability. ...

If the loan is considered received because of shareholdings, the [exempting] CRA administrative policy does not apply. ...

Since the supplier simply contacts the common carrier to inform them that the good is ready for pick up, the supplier is not considered to have retained the carrier on behalf of the recipient. ...

For example, one of the results of making the election is that the units of the series held by a non-resident person that is an individual or specified investor, or units of an exchange-traded series held by a non-resident person would not be deemed to be held by an individual resident in Canada that is not resident in any participating province for the purpose of the SLFI Regulations and would continue to be considered units held by a non-resident of Canada. ...

However, if an employer is interested in participating, the amount paid by the employer will be considered as a taxable benefit to the employee and included on the employee's T4 as income. ...

P-099 "The Meaning of 'Hotel', 'Motel', 'Inn', 'Boarding House', 'Lodging House' and 'Other Similar Premises', as used in the definition of 'Residential Complex' and 'Residential Unit'" 16 December 1993-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex The determination of whether an establishment is a hotel, motel, inn, boarding house, lodging house or other similar premise, should be based on...all the following guidelines.... the establishment normally provides temporary accommodation rather than a permanent place of residence; where required by municipal and/or provincial regulations, the establishment is licensed for business for the purpose of providing a temporary place to stay; the establishment is available for rental to the public on a temporary [transient] basis [For this purpose, the public is considered to be either the community as a whole or a defined class of the public, such as students or senior citizens. ...

Imposing such penalty would only occur in the context of a compliance action, such as an audit, where all factors and circumstances of the taxpayer’s particular situation are considered together. ...