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CRA stated: …[A] trust is considered to be governed by a registered pension plan if the trust holds all the property of a pension plan and is governed by its own written terms (i.e., trust agreement). ...

30 December 2013 Ruling 136499-- summary under Subsection 272.1(1) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(1) distributions to GP of portion of LP set-up fees were taxable A limited partnership (the “Partnership”) engaged in lending money and received “Set-Up” fees from the borrower, which were considered by CRA to be part of the consideration for its supply of financial services. ...

16 March 2016 Ruling 158766-- summary under Section 15 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 15 services re TPP if they “serve a particular need…relating to the property” After ruling that “each [on-site and off-site] supply of [Service X] made by [ACo] is a service in relation to TPP that is made in the province where the TPP, to which the services relate, is situated at the time the services are performed,” CRA provided a general discussion of the relationship between s. 15 and s. 16, and stated: [W]hether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the property, taking into account the objectives of the service and the particular circumstances of each case. ...

In other words, an organization which has not been empowered by a legislative statute to regulate a particular profession or trade will not be considered to be a regulatory body for the purposes of section 6 of Part III. ...

CRA responded: Below are some examples of factors that may be considered…: First occurrence vs multiple instances of similar errors; Voluntary disclosure vs adjustment detected via audit work; Adjustments made due to errors vs adjustments due to unreported/misreported transactions; Materiality of the false statement or omission; Whether the registrant was contacted by CRA in the past regarding the issue at hand; Expected level of registrant's knowledge of GST/HST matters; Degree of registrant's involvement in preparing the GST/HST return; Whether the registrant attempted to correctly apply the ETA and inadvertently misinterpreted it; Whether sufficient books and records were maintained; and Compliance history of the registrant. ...

CRA responded: Below are some examples of factors that may be considered…: First occurrence vs multiple instances of similar errors; Voluntary disclosure vs adjustment detected via audit work; Adjustments made due to errors vs adjustments due to unreported/misreported transactions; Materiality of the false statement or omission; Whether the registrant was contacted by CRA in the past regarding the issue at hand; Expected level of registrant's knowledge of GST/HST matters; Degree of registrant's involvement in preparing the GST/HST return; Whether the registrant attempted to correctly apply the ETA and inadvertently misinterpreted it; Whether sufficient books and records were maintained; and Compliance history of the registrant. ...

However, in the absence of direct evidence to support the position that this is the case we…conclude that Executor B performed the executor services in relation to an office and he is not considered to have made a taxable supply…. ...

(a) as being used for the purpose of providing medical care, CRA stated: In these cases [Riverfront and P-248] the examination by a physician or the review of a patient’s medical records by a physician were considered to be medical care for purposes of the definition of “health care facility.” ...

The PSB is also considered to have paid GST on the equipment's fair market value of $25,000. ...

CRA indicated that two examples of what could be considered “beyond the taxpayer’s control” are: A taxpayer makes a disclosure for their un-filed returns for the past four years. ...