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., a person who is no longer a partner at the payment time), including payments to which ITA s. 96(1.1) applies, considered to be for an exempt supply of a financial service? ...

27 February 2020 CBA Roundtable, Q.24-- summary under Subsection 179(9) Summary Under Tax Topics- Excise Tax Act- Section 179- Subsection 179(9) s. 179(9) does not affect whether a non-resident lessor is carrying on business in Canada Example 1 in Policy Statement P-051R2 indicates that a non-resident lessor (with a leasing business outside Canada) is considered to be carrying on business in Canada by virtue of a sale-leaseback transaction under which it purchases a conveyance from a resident registrant, with delivery under the sale agreement and under the lease-back to the resident (who will use the conveyance partly in Canada) occurring in Canada, notwithstanding no other significant connecting factors to Canada. ...

CRA responded: In circumstances where a partnership-owned passenger vehicle is used personally by a member of the partnership (or an employee of a member of the partnership), the partnership is not entitled to an input tax credit on the acquisition or importation of the passenger vehicle by virtue of subsection 202(2) of the ETA since that use is considered not to be use in the partnership's commercial activity. ...

Such a trust will be considered a trust created by the taxpayer’s will and thus may qualify as a spousal trust if other conditions are met. ...

To be considered charitable, a charity must meet the “public benefit” test. ...

CRA indicated that “construction” is “the creation of something new, and can be distinguished from repair, improvement, recombining or rearranging of something that already exists,” and that: A substantial renovation is generally considered to have taken place where all or substantially all of the interior of a residential condominium unit has been removed or replaced and, upon completion, the renovated or altered unit is, or forms part of, a residential complex. ...

. • You are not registered for the GST/HST and you purchased the real property from a person who is not resident in Canada, or from a person who is considered to be resident only for activities carried on through the person's permanent establishment in Canada. • You are not registered for the GST/HST and you purchased taxable supplies of emission allowances that are made in Canada ...

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024-- summary under Subsection 402(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(6) Allocation under Reg. 402(6) in accordance with income-sharing percentage 2.71 Each member of a partnership is considered to have a permanent establishment in the province(s) in which the partnership has a permanent establishment. ...

For instance, if as a matter of fact, the right that is supplied could only ever be used from a single location in a single province, then the use of the right would be considered to be limited to that province regardless of whether this is explicitly stated in the terms of the agreement. ...

A residential property is considered to be substantially completed even if there are outstanding minor repairs, adjustments or upgrades, since this will not reasonably impair the use and enjoyment of the property as a place of residence. ...