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Also, given that a bare trustee is controlled by its beneficiaries, it is not considered as being "responsible for the managerial or operational control of the joint venture" as described in paragraph (b) of the CRA's interpretation of the term "participant". Consequently, a bare trustee cannot be considered as a "participant" to a joint venture for the purposes of subsection 273(1)…. ...

Therefore, the amount of property taxes payable by a tenant is considered to be part of the rent and is subject to GST/HST in the same way as the amount of rent payable by the tenant. This will be the case whether or not the rental agreement states that the payment of property taxes by the tenant is to be considered as "rent" or "additional rent. ...

CRA responded: The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property…. ... …[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. ...

CRA responded: The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property…. ... …[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. ...

…[T]he CRA's 95(6)(b) Committee intends to review cases and assess whether they include a share investment or divestment in a foreign affiliate that could be considered to have been for the principal purpose of manipulating share ownership in the affiliate in order to secure a tax benefit, such as for example, a subsection 113(1) deduction for a stream of dividends. This may be the case where it could be considered that the share ownership in the foreign affiliate is transitory on the basis that it is reasonable to conclude that a subsequent disposition was contemplated at the outset. ...

.-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) 13....Foreign currency funds on deposit are not considered to be disposed of until they are converted into another currency or are used to purchase a negotiable instrument or some other asset, i.e. foreign funds on deposit may be moved from one form of deposit to another as long as such funds can continue to be viewed as "on deposit". Term deposits, guaranteed investment certificates and other similar deposits which are in fact not negotiable, are considered funds on deposit. ...

For example, a foreign corporation with a branch that is a permanent establishment under subsection 123(1) located in Canada is not a resident of Canada but is considered a non-resident with a permanent establishment in Canada. ... For example, a corporation resident in Canada with a branch that is a permanent establishment under subsection 123(1) located in another country is not considered to be a non-resident. ...

However, where the Department is satisfied that a property is held in trust solely to carry out the terms of a will under which the ultimate and absolute ownership of that property is bequeathed to a particular individual and the trust arrangement is such that the individual's ownership rights cannot be defeated by any future event and no other person has any right whatsoever to an immediate or future benefit from that property or that trust, the property will be considered to vest indefeasibly in that individual. 2. Property is considered to vest indefeasibly in the person to whom it is bequeathed when that person has an enforceable right or claim to the ownership thereof. ...

CRA responded: The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property…. ... …[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. ...

Treaty, CRA has considered many strategies designed to ensure that either Art. ... Among the strategies previously considered, the CRA is aware of some structures designed to avoid the application of para. (7) through the introduction of an interposing entity located in a third jurisdiction. ...