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Administrative Policy summary
23 May 2013 IFA Round Table, Q. 10 -- summary under Article 5
CRA considered the fixed base PE provision in para. (1) of Art. V, the agency PE provision in para. (5), and the services PE provision in subpara. (9)(b), and ruled that USco would not carry on a business through a PE in Canada. ...
Administrative Policy summary
26 February 2015 CBA Roundtable, Q. 13 -- summary under Subsection 273(1)
Could both the Initial and Subsequent Agreements collectively be considered “an agreement” for purposes of s. 273(1) so that s. 273(1)(c) could apply? ...
Administrative Policy summary
Memorandum D11-6-3 Administrative Policy Respecting Re-determinations or Further Re-determinations Made Pursuant to Paragraph 61(1)(c) of the Customs Act 16 September 16 2008 -- summary under Paragraph 61(1)(c)
They should contact their regional Recourse Division for written confirmation that the goods in question are considered to be subsequent goods or, alternatively, file timely dispute notices under section 60, or applications for refund under paragraph 74(1)(e). ...
Administrative Policy summary
GST/HST Memorandum 16.3.1 [16-3-1] “Reduction of Penalty and Interest in Wash Transaction Situations” April 2010 -- summary under Subsection 281.1(1)
The waiver of interest in excess of 4% of the tax not properly charged in a wash transaction will normally be considered automatically by the CRA during the audit process. ...
Administrative Policy summary
7 April 2016 Interpretation 167824 Certifications and Examinations -- summary under Section 6
In finding that the supply of the exam was not exempted, CRA stated: …[A]n 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. ...
Administrative Policy summary
GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017 -- summary under Subsection 175(1)
Pursuant to section 175, the charity is deemed to have received a supply of the car rental, and the use of the car by the volunteer for the two days is considered to be use by the charity. ...
Administrative Policy summary
May 2016 Alberta CPA Roundtable, Q.15 -- summary under Subsection 15(1)
In addition, the T2200 and T777 would only apply to situations where the shareholder is also considered an employee of the corporation. ...
Administrative Policy summary
25 February 2016 CBA Roundtable, Q. 7 -- summary under Paragraph (c)
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. ...
Administrative Policy summary
28 April 2017 Interpretation 154249 -- summary under Recipient
. … Consequently, the Assignee is not considered the recipient of the supply of software licences and is not entitled to claim an ITC for the GST/HST paid for them to the Vendor. ...
Administrative Policy summary
8 September 2017 Interpretation 180362 -- summary under Section 144
Would such supply be considered to be made outside Canada by virtue of s. 144? ...