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Since NewCo thus is not considered to have constructed or substantially renovated the residential complex, it is not a “builder” under paras. ...

Generally, a supply of intangible personal property is considered to relate to tangible personal property if the intangible personal property relates to specific tangible personal property. ...

GST/HST Technical Information Bulletin B-092, Substantial Renovations and the GST/HST New Housing Rebate, January 2005-- summary under Substantial Renovation Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Substantial Renovation Recap of s. 123(1) definition In other words, a substantial renovation is considered to have taken place where all or substantially all of the interior of a building, with the exception of certain structural components (the foundation, external walls, interior supporting walls, roof, floors and staircases), has been removed or replaced. ...

Any postponement under this subsection requires approval of the appropriate delegated authority … Specific to the postponement of GST/HST amounts owing which have been objected to, where the taxpayer is unable to provide security in a form and amount satisfactory to the Minister, postponement will only be considered where: the registrant remains current with tax compliance requirements for all associated accounts the GST/HST amounts in dispute have not already been collected by the registrant at all times during the objection and/or appeal, the business remains in good financial standing the registrant provides relevant information after an assessment is raised that may result in the assessment being overturned the registrant’s objection and/or appeal identifies reasonable differences in the interpretation of the legislation the registrant has Canadian-based assets The decision to postpone collection action without the acceptance of security is a local business decision made on a case-by-case basis, based on the facts of each specific account. ...

CRA indicated: When there is a disposition of a capital interest in a trust because of a distribution from a trust, the purchaser for s. 116 purposes is considered to be the trust or estate. ...

Ex. 1 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. ...

Instead, as the employer, partnership, charity or public institution would be considered to be the recipient of the supply, the usual rules for determining whether that person was eligible to claim ITCs or rebates would apply. ...

(iii) A final bona fide repayment would not be considered part of a series for the purpose of s. 212.3(10)(c)(i), so that a particular amount owing by a subject corporation to a CRIC which arose in the ordinary course of its business of the CRIC would meet the exception if its final bona fide repayment was made within 180 days after the day on which it became owing. ...

In situations where some proportion of shares is being replaced with borrowed money, only the capital of those shares, computed on a pro-rata basis, would be considered to be replaced with the borrowed money. ...

Where the terms of an exchangeable share permit the taxpayer to exchange its shares with the issuer for shares of another company, would ancillary rights enabling such taxpayer to put its shares to another person for the shares of the other company in the event the issuer is unable to effect the exchange be considered to be an agreement for purposes of the DFA definition? ...