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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. ...

As the agent can recover the respective portions of the remittance from the other dentists, we consider that the agent is being reimbursed for amounts it pays on behalf of these other dentists, who would be considered to be principals. ...

Moreover, the sale of the undivided interest in Example 1 that is considered to be a supply of a business or part of a business includes the interest in and to the leases, lands, and petroleum substances, and tangible property for the production and processing of petroleum substances. ...

…By way of illustration…: [A] right should not be considered a "specified right" simply because the right secures debts that the shareholder of the corporation and the corporation itself owe to a financial institution. ...

As a corollary, according to this same tax policy, the balance of the taxable income of a trust that cannot be considered to have become payable to the beneficiaries is then taxable in the hands of the trust. ...

CRA considered that the addition to the capital dividend account (CDA) of each of Corporation B and Corporation C was $300,000 (=$500,000-$200,000), not $400,000, i.e., the full ACB reduces the CDA addition for each rather than being prorated. ...

. … Some factors to be considered, but not limited to, include: the total number of supplies made and the total value of the revenue received from supplies made in each business activity; the relative value of the assets employed in each business activity; the commercial practices of the person, including the time, attention, and efforts expended by the employees, managers, or corporate officers in each business activity; and the terms of any partnership agreement if the person is a partnership, or corporate objects in the case of a corporation. ...

CRA responded: In accordance with section 271, for the purposes of applying the GST/HST provisions in respect of property or a service acquired, imported or brought into a participating province by a predecessor, the new successor corporation is considered to be the same corporation as and a continuation of each of the predecessors. ...

X, however, is considered to be a builder in his own right (for example, at the time of entering into the agreement of purchase and sale, he did so for the primary purpose of selling the interest or the house itself), tax would be payable by the Vendor calculated on the value of consideration ($100,000) for the supply. ...