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Generally, upon entering into an agreement for the construction and sale of a new house, the first purchaser is considered to have acquired an interest in the house. For GST/HST purposes, the assignment of the agreement to the assignee purchaser is normally considered to be a sale of the first purchaser's interest in the new house. ...

Would its principal business be considered to be lending under s. 149(1)(a)(viii)? After noting that the factors which CRA would consider in comparing two business activities in the context of a principal business determination include the relative revenues and number of supplies made, assets, and time and efforts required, CRA stated that, in this holding company example, “there are a number of factors to be considered in making this determination,” and insufficient information was provided. ...

Are such contributions considered to fall under the word “settles”? CRA responded: Any transfer of assets into the trust by the original settlor (such as X in the question) upon its establishment or at a subsequent point in time, would be considered to fall within the meaning of the term "settles" and be subject to section 268. ...

I, s. 9(2) as a supply by way of sale of real property if the site had only ever been used for personal use (rather than rented out), CRA stated: For GST/HST purposes, a sub-leasehold interest in real property is considered to be real property, and an assignment of the sub-leasehold interest by a sub-leaseholder is generally considered to be a sale of real property. ...

CRA somewhat generously considered that all of these items fell within the listed s. 135 items other that the exhibition booth, which it characterized as a supply of real estate. ... These packages are all considered a single supply of promotional services, because, amongst other things, it is not possible for a sponsor to choose which benefit it wants and to only pay that price. ...

28 February 2019 CBA Roundtable, Q.19-- summary under Subsection 281.1(1) Summary Under Tax Topics- Excise Tax Act- Section 281.1- Subsection 281.1(1) CRA considered, and declined, extending its wash-trading policy to supplies made to municipalities Memorandum 16-3-1, para. 4 lists municipalities, which are eligible for 100% GST rebates, as entities that cannot be considered to have received a wash transaction. ...

An RJO can hold an interest in a partnership and it will not be considered to be carrying on a business activity if it meets all of the following conditions: the RJO’s liability as a member of a partnership is limited under any law governing the arrangement in respect of the partnership; the RJO and all non-arm’s length entities collectively hold 20% or less of the interests in the limited partnership; and the RJO deals at arm’s length with each general partner of the limited partnership. 5.15. An RJO that acquires and holds a partnership interest beyond these limits would be considered to be carrying on the business of the partnership. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Subsection 191(3) Summary Under Tax Topics- Excise Tax Act- Section 191- Subsection 191(3) supplies acquired prior to self-supply time generate ITCs even if only invoiced later Where a builder was invoiced, after the time that it self-assessed for the fair market value of a newly-constructed multiple unit residential complex (at the time of substantial completion and first tenant occupancy) for work done before that time, CRA explained the availability of an input tax credit therefor on the basis that, by virtue of s. 133: where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time). ...

… Once an eligible employer has determined that it has experienced the required reduction in revenue for a particular claim period, it is automatically considered to have experienced the required reduction in revenue for the immediately following claim period (deeming rule). As a result, the employer does not have to make this determination again for that next claim period …. … In a situation where the eligible employer, subsequently determines that it actually experienced the required reduction in revenue, without applying the deeming rule, for the second claim period- April 12 to May 9, 2020, the eligible employer will be considered to have experienced the required reduction in revenue for that third claim period because of the deeming rule that can now be applied to the third period …. ...

27 February 2020 CBA Roundtable, Q.4-- summary under Paragraph 179(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 179- Subsection 179(1)- Paragraph 179(1)(b) meaning of causing physical possession transfer in s. 179(1)(b) What factors should be considered in determining whether a registrant “causes physical possession of the particular property to be transferred” for purposes of s. 179(1)(b)? ... Generally, a registrant who has physical possession of the tangible personal property and transfers physical possession of the property would be considered to have caused physical possession of the property to have been transferred for purposes of paragraph 179(1)(b).... ...