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Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Use of a Partner's Assets by a Partnership"-- summary under Paragraph 1102(1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(1)- Paragraph 1102(1)(c) Where a property is acquired by a partner for the purpose of making it available to the partnership to be used in carrying on the business of the partnership, that property will be considered to have been acquired by the partner for the purpose of earning income if the partnership business is carried on with a view to profit, notwithstanding that the partner does not charge rent to the partnership. ...

16 August 1994 Headquarter Letter-- summary under Subsection 169(4) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(4) In a situation where an unregistered non-resident was listed as the importer of record, and it supplied goods to a registrant who wishes to obtain an ITC under s. 180, CCRA indicated that "a copy of the B3 Customs Coding Form will be considered sufficient evidence for purposes of paragraph 169(4)(a) and subparagraph 180(a)(ii) of the Act.... ...

16 August 1994 Headquarter Letter-- summary under Section 180 Summary Under Tax Topics- Excise Tax Act- Section 180 In a situation where an unregistered non-resident was listed as the importer of record, and it supplied goods to a registrant who wishes to obtain an ITC under s. 180, CCRA indicated that "a copy of the B3 Customs Coding Form will be considered sufficient evidence for purposes of paragraph 169(4)(a) and subparagraph 180(a)(ii) of the Act.... ...

11 February 1993 Memorandum (Tax Window, No. 29, p. 9, ¶2428)-- summary under Paragraph 108(2)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(a) suspension of redemptions when suspension in trading The requirements of s. 108(2)(a)(i) will be considered to be met even though the administrator of the unit trust may suspend redemption of units when normal trading is suspended in securities held by the fund that represent more than 50% of its total net assets, or during any period not exceeding 120 days during which the fund administrator determines that disposal of this portfolio of securities is not reasonably practicable, or that it is not reasonably practicable to determine fairly the net asset value of the fund. ...

Such an arrangement generally would not be considered to result in an abuse for purposes of s. 245(4). ...

After ruling that the compensation received by Corporation A from the bank is consideration for a single taxable supply, CRA stated: [Corporation A's] activities...are predominantly promoting and marketing the Program....Also [Corporation A] is not in the business of providing supplies of financial services or considered a financial intermediary as described under subparagraph 149(1)(a)(iii). ...

.- Q. 8 (File 932812)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Interest payable on funds borrowed to purchase newly-issued preferred shares that provide for dividends on the board's discretion and that are only entitled to a return of the subscription price on dissolution of the corporation will, in general, be considered by RC not to have been acquired for the purpose of earning income, with the result that the interest on funds borrowed to acquire the shares will only be deductible to the extent of the dividend income. ...

GST/HST Memoranda Series 2.7 Cancellation of Registration May 2005-- summary under Section 271 Summary Under Tax Topics- Excise Tax Act- Section 271 •If two or more corporations amalgamate, the successor company is a new entity and is considered to be a person separate and distinct from each of its predecessor corporations. ...

5 February 2016 Interpretation 153241-- summary under Subsection 13(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 13- Subsection 13(1) situs of medical evaluation for insurer based on its address rather than patient's CRA considered that independent medical evaluations (IMEs) supplied by non-employee doctors to insurance companies or lawyers after March 21, 2013 were not exempt health supplies. ...

3 April 2017 Interpretation 164742-- summary under Subsection 225(1) Summary Under Tax Topics- Excise Tax Act- Section 225- Subsection 225(1) litigant receiving a court award of costs plus GST/HST is not required to report such tax CRA considered that as court awards of costs (including any award on a solicitor and client scale) “do not constitute consideration for a taxable supply or a service and do not form part of the consideration paid for the lawyer’s services of the winning party,” that party is not required to account for any GST or HST in computing its net tax for the reporting period in question, even where the award of such costs included a GST or HST amount. ...