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In other cases, a printed book and another item packaged together and sold for a single price will be considered to be two separate items. ... If the supply of the other item is incidental to the supply of the printed book, then the entire product will be considered to be one supply of a printed book. Conversely, if the printed book supply is incidental to the supply of the other item, then no part of the supply will be considered to be that of a printed book. ...

Other application of sale In the common law provinces, legal and equitable interest[s] in real property [are] specifically considered "real property" within the meaning of paragraph (b) of the definition of real property in subsection 123(1) of the Act. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

Other application of sale In the common law provinces, legal and equitable interest[s] in real property [are] specifically considered "real property" within the meaning of paragraph (b) of the definition of real property in subsection 123(1) of the Act. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

In suggesting that the fees received by the Acquirer may be for financial services, CRA states: Since the ISO is not considered an Acquirer and is therefore prohibited from performing the Payment Processing Service for the Merchant, a second agreement was entered into with the Acquirer. ... Moreover, paragraph (t) may not apply to exclude the Acquirer's Payment Processing Service from the definition of a financial service if the Acquirer is considered a person at risk with respect to the issuance of an instrument (i.e., where the Acquirer is financially at risk of any loss until the transactions have gone through the settlement process). ... Respecting the ISO, CRA stated: Even though the ISO's service provided to the Merchant under the Agreement may also be considered the agreeing to provide or arranging for a financial service under paragraph (l), paragraph (t) may apply to exclude the service as a financial service if the ISO's service, when considered as a whole, is predominantly the transfer, collection or processing of information and/or an administrative service performed by a person who is not at risk (i.e., where the ISO is not financially at risk when it provides these services to the Merchant). ...

27 February 2020 CBA Roundtable, Q.17-- summary under Paragraph 132(1)(a) Summary Under Tax Topics- Excise Tax Act- Section 132- Subsection 132(1)- Paragraph 132(1)(a) a Canadian Amalco was “incorporated” in Canada- and if continued elsewhere, may still have central management and control in Canada (a) Is a corporation formed by the amalgamation of one or more corporations, pursuant to the laws of Canada or a province, considered to be “incorporated” in Canada and, therefore, deemed by s. 132(1)(a) to be resident in Canada (having regard inter alia to Deltona, which considered the formation by amalgamation of a corporation to be its “incorporation”), provided it is not continued elsewhere; and (b) Is a corporation incorporated in Canada that was continued in a jurisdiction outside Canada considered to be resident in Canada, if its central management and control is exercised in Canada, or to the extent that it maintains and carries on activities through a permanent establishment in Canada? ... Where two or more Canadian corporations amalgamate under the rules for amalgamation set out in the Canadian federal or provincial statute under which they were incorporated, and a certificate of amalgamation is issued, the amalgamated corporation will generally be deemed to be resident in Canada because it would be considered to be incorporated in Canada. b) A corporation incorporated in Canada that is continued in a jurisdiction outside of Canada would not be deemed, under subsection 132(1)(a), to be resident in Canada. However, such a corporation may be considered resident in Canada if the central management and control of the activities of the corporation is exercised in Canada. ...

.- Q.26-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where an amalgamation does not qualify under s. 87 and, under the governing corporate law, the amalgamated corporation is considered to be a continuation of its predecessors, the predecessor corporations generally will not be considered to have disposed of any assets held immediately before the amalgamation. However, shareholders of each predecessor generally will be considered to have disposed of their shares for capital gains purposes. ...

.- Q.26-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) Where an amalgamation does not qualify under s. 87 and, under the governing corporate law, the amalgamated corporation is considered to be a continuation of its predecessors, the predecessor corporations generally will not be considered to have disposed of any assets held immediately before the amalgamation. However, shareholders of each predecessor generally will be considered to have disposed of their shares for capital gains purposes. ...

GST/HST Notice No. 303- Changes to the Closely-related Test-- summary under Subparagraph 128(1.1)(a)(i) Summary Under Tax Topics- Excise Tax Act- Section 128- Subsection 128(1.1)- Paragraph 128(1.1)(a)- Subparagraph 128(1.1)(a)(i) exception for special voting matters provided by statute, or where a statute provides a special class vote Exception for special voting matters provided by statute, or where a statute provides a special class vote Thus, in order for a person (or group of persons) to be considered to hold qualifying voting control of another corporation, 90% or more of shareholder votes in respect of all corporate matters must be held and controlled by the person, with limited exceptions. Where there are any matters in respect of which a statute of a country, state, province, or other political subdivision of a country, that applies to the corporation provides that the votes of the shareholders of the corporation in respect of the matter are different from the voting rights that the shareholders would otherwise have pursuant to the corporation’s constating documents, then that matter is not considered for the purposes of determining whether a particular person holds qualifying voting control in respect of the corporation. ... Therefore, the distribution of voting rights in respect of the shareholders vote on an amalgamation agreement is not considered when determining whether a person holds qualifying voting control of a corporation. … [T]he matters listed in subsection 176(1) of the Canada Business Corporations Act entitling the holders of shares of a class or series to vote separately as a class or series are not considered for purposes of determining whether a person holds qualifying voting control of the corporation. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 s. 133 determines time of acquisition for ITC purposes In finding that input tax credits can generally be claimed by a builder for invoices issued subsequent to the date of self assessment on substantial completion and first occupancy of a multiple unit residential complex (a “MURC”) for work done by suppliers for goods and services sold/installed performed prior to the first tenant move-in, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. Therefore, where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time). The time at which the consideration for a supply of property or a service becomes due under section 152 … does not impact the time at which the supply is considered to be made, nor does that time impact the purpose for which the recipient of the supply acquired the property or service. … ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) purpose of acquisition is assessed at time agreement is entered into In finding that input tax credits can generally be claimed by a builder for invoices issued subsequent to the date of self assessment on substantial completion and first occupancy of a multiple unit residential complex (a “MURC”) for work done by suppliers for goods and services sold/installed performed prior to the first tenant move-in, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. Therefore, where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time). The time at which the consideration for a supply of property or a service becomes due under section 152 … does not impact the time at which the supply is considered to be made, nor does that time impact the purpose for which the recipient of the supply acquired the property or service. … ...