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If for any reason the transferee corporation does not obtain, under the applicable corporate legislation, the necessary authorization for the issuance of the shares, the election under subsection 85(1) will be considered to be invalid. ...

4 December 1995, November TEI Round Table, Q. 4, 953042-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) In response to a question as to whether compensation payments made under a securities loan from a related non-resident corporation should be viewed by as either "any payment for the use of or for the right to use in Canada any property" (under s. 212(1)(d)(i)) or "any payment that was dependent on the use of or production from property in Canada" (under s. 212(1)(d)(v)), CRA responded: Where the borrower pays the non-resident lender a fee ("lending fee" or "borrowing fee") for entering into the arrangement, it is our view that the fee would generally be considered to be for the use of or the right to use property in Canada and as such would be subject to withholding tax pursuant to subparagraph 212(1)(d)(i) of the Act. ...

In finding that the "optioning" under the agreement by the Optionor was a provision of natural resource rights in respect of an unproven property which s. 162(2)(a) deemed not to be a supply, CRA stated: Strictly speaking, an option to acquire something is not necessarily the same as acquiring the thing itself and an option to acquire something is generally considered to be a supply. ...

.'s activities when considered as a whole are predominantly managing and administering on behalf of the Lenders an electronic loan application system for the Program. ...

The amount that a trust can designate in respect of a particular beneficiary is limited to the portion of the trust's income for the year from a source in a country other than Canada that can reasonably be considered (having regard to all the circumstances including the terms and conditions of the trust arrangement) to be part of the income that was included in the beneficiary's income by virtue of subsection 104(13) or (14)…; and is not designated by the trust in respect of any other beneficiary. ...

Such credits are purchased as a compliance measure and are not considered a penalty under the relevant provincial climate change legislation. ...

When assessing private benefit, the Charities Directorate considers the following factors: the extent to which the private benefits are considered incidental; the degree to which the private benefits further the organization's charitable purpose; and whether the amount of private benefit is ancillary and incidental to the charitable purpose, and is reasonable. ...

In most instances, charities are provided with an opportunity to correct their actions through education or compliance agreements before other measures are considered. ...

GST/HST Notice 284 "Bare Trusts, Nominee Corporations and Joint Ventures" February 2014-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) administrative tolerance for nominee operators After repeating its position that participants in joint ventures may not elect "for a nominee corporation or bare trust to be the operator of the joint venture where the nominee corporation or bare trust does not have the managerial or operational control," and noting that "where the person does not engage staff to perform any of the operator's duties, it is doubtful that the person would be considered to have the managerial or operational control," CRA stated: Auditors have been advised not to assess for any GST/HST owing where an assessment could be raised because the bare trust or nominee corporation is not a participant for purposes of section 273. ...

Excise and GST/HST News- No. 97 17 November 2015-- summary under Practitioner Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 1- Practitioner Acupuncturists as practitioners A person is considered to be licensed or certified to practise the profession of acupuncture if he or she is licensed or certified as an acupuncturist or as a Traditional Chinese Medicine (TCM) practitioner by a provincially established regulatory body, if the acupuncture service is supplied in a province that regulates the profession of acupuncture. … Currently, the profession of acupuncture is regulated under provincial legislation in the provinces of British Columbia, Alberta, Ontario, Quebec and Newfoundland and Labrador. ...