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Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 2 -- summary under Subsection 177(1.1)
In responding negatively, CRA stated: [I]t is unclear how BCo could be considered to have charged and collected the consideration and tax payable from itself in respect of a supply made by ACo as required under subsection 177(1.11). ...
Administrative Policy summary
31 July 2012 Interpretation Case No. 103548 -- summary under Section 20
Such a levy would generally be considered to be for an exempt supply under Sched. ...
Administrative Policy summary
Land Transfer Tax and the Treatment of Unregistered Dispositions of a Beneficial Interest in Land 6 April 2022 -- summary under Regulation 70/91 [s. 3 exemptions]
Entitlement to profit is considered by the ministry to be an entitlement to what, in accounting terms, amounts to net earnings. ...
Administrative Policy summary
May 2013 ICAA Roundtable, GST Q. 9 (reported in April 2014 Member Advisory) -- summary under Section 5
CRA responded: A dental procedure that is performed solely to improve the appearance of a person's teeth, gums or bite (and have no underlying medical or reconstructive purpose) would be considered a cosmetic service supply. ...
Administrative Policy summary
IT-188R Archived "Sale of Accounts Receivable" 22 May 1984 -- summary under Account Receivable
Where in the ordinary course of business a taxpayer discounts customer's trade paper such as notes and bills receivable, the amount of the discount is considered to be a deductible business expense, not a capital loss. ...
Administrative Policy summary
IT-338R2 -- summary under Subsection 103(1)
For example, the partnership agreement may state that when a property is transferred under this provision and is subsequently disposed of by the partnership, any resulting profit or gain will, to the extent it is considered to have accrued prior to the date on which the property was transferred to the partnership, be allocated entirely to the partner who contributed that property. ...
Administrative Policy summary
IT-65 "Stock Splits and Consolidations" 8 September 1972 (Archived) -- summary under Disposition
IT-65 "Stock Splits and Consolidations" 8 September 1972 (Archived)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where all the shares of a class of stock of a corporation are replaced by a greater or lesser number of shares of the same class of stock of the same corporation in the same proportion for all shareholders, in circumstances where there is no change in the total capital represented by the issue, there is no change in the interest, rights or privileges of the shareholders and there are no concurrent changes in the capital structure of the corporation or the rights and privileges of other shareholders, no disposition or acquisition is considered to have occurred. ...
Administrative Policy summary
Interpretation Revenu Québec TVQ. 16-30/R1 "Nominee Agreements" 9 December 2011 -- summary under Agency
Where a nominee is entrusted with the management of an immovable by its owner and empowered to represent the owner for the purposes of entering into leases and collecting rents, which are juridical acts, supplies of immovables made by way of lease through the nominee are considered to have been made by the owner of the immovable. ...
Administrative Policy summary
19 September 1990 Memorandum ACC 96248 -- summary under Paragraph 12(1)(x)
It is a question of fact, in any given set of circumstances, whether or not a loan can be considered to be unconditionally repayable. ...
Administrative Policy summary
93 C.P.T.J. - Q. 37 -- summary under Subsection 15(1)
However, where all shareholders, including those who are not employees, are given the identical right per common share to acquire additional shares, the rights given to employee-shareholders would not ordinarily be considered to have been received in respect of employment. ...