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Administrative Policy summary
GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015 -- summary under Section 21
If there is a termination or stopover outside Canada in respect of the continuous journey, then the supply of the passenger transportation service is considered to be made in a non-participating province, regardless of the province in which the continuous journey originates. ...
Administrative Policy summary
GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015 -- summary under Section 3
Generally, the supply of a charter flight to a third-party charterer is considered to be a supply of a passenger transportation service. ...
Administrative Policy summary
IT-206R "Separate Businesses" -- summary under Paragraph 4(1)(a)
When determining the degree of interconnection, interlacing, or interdependence between simultaneous business operations, factors to be considered could include, but are not to be restricted to, the following: (a) The extent to which the two operations have common factors that may be pertinent. ...
Administrative Policy summary
GST/HST Memorandum 3.3 "Place of Supply" April 2000 -- summary under Paragraph 142(1)(b)
This determination would govern whether all the deemed supplies made under the arrangement was considered to be made in or outside Canada, irrespective of whether the property was situated in Canada during some lease intervals and outside Canada during others. ...
Administrative Policy summary
P-169R Meaning of in Respect of Real Property Situated in Canada and in Respect of Tangible Personal Property that is Situated in Canada at Time the Service is Performed, for Purposes of Schedule VI, Part V, Sections 7 and 23 to the Excise Tax Act -- summary under Section 23
The relationship between the service and the real or tangible personal property must be more direct than indirect in order for the service and the property to be considered by the Department to be "in respect of" each other. ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 20. ("Reorganizations - Amalgamations") -- summary under Subsection 167(1)
Since a predecessor corporation (in this case, Opco) is the entity that established or carried on the business, the Amalco cannot be considered to have done so, since it is deemed to be a separate person for GST/HST purposes. ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 20. ("Reorganizations - Amalgamations") -- summary under Section 271
Since a predecessor corporation (in this case, Opco) is the entity that established or carried on the business, the Amalco cannot be considered to have done so, since it is deemed to be a separate person for GST/HST purposes. ...
Administrative Policy summary
IT-365R2 "Damages, settlements, and similar receipts" 8 May 1987 -- summary under Compensation Payments
If the receipt relates to the loss of an income-producing asset, it will be considered to be a capital receipt; on the other hand, if it is compensation for the loss of income, it will constitute business income. ...
Administrative Policy summary
GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001 -- summary under Section 9
Diagram 1A Lot D is considered to be one parcel of land. D is then subdivided or severed into three parts described as lots E, F and G. ...
Administrative Policy summary
23 May 2013 IFA Round Table, Q. 10 -- summary under Article 5
CRA considered the fixed base PE provision in para. (1) of Art. V, the agency PE provision in para. (5), and the services PE provision in subpara. (9)(b), and ruled that USco would not carry on a business through a PE in Canada. ...