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8 August 2002 Ruling Case No. 31015-- summary under Section 6 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part I- Section 6 A registrant upon completion of construction of a nursing home would not be entitled to the new housing rebate under s. 256.2 (and also would not be required to self-assess under section 191) because the subsequent supplies it made to residents of the facility would not be considered to be described in section 6. ... Accordingly the registrant would be considered to be making a single supply that was not simply that of accommodation as set out in section 6. ...

2009 Ruling 2008-0304371R3- Single-Wing Butterfly-- summary under Distribution Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Distribution net receivables and prepaids of rental company reclassified as business property In a single-wing butterfly of a company whose assets consisted of cash and cash equivalents, tenant receivables and a revenue producing rental property, the revenue-producing properties and prepaid rent were considered business property and loans receivable from certain Holdcos, which had no specified terms of repayment, were considered to be near cash assets. ...

Rulings that "D Co will not be considered to have disposed of its shares of G Co or H Co as a result of its conversion from a corporation to an LLC…" and "following its conversion…D Co will be considered to be the same corporation that it was prior to the conversion. ...

Since a contingent amount would not be considered "payable," until an additional payment is paid or becomes payable, the periodic interest would not be considered participating debt interest. However, once an additional payment is paid or becomes payable, the periodic interest on such obligation would be considered participating debt interest from that point of time onwards. ...

“shareholders” of Dutch co-op (DC) of FAs in consideration for proportionate “increases” in their membership interests considered to be for “shares” Proposed Transactions Holdco (resident in Canada) transfers a portion of its shares of a Netherlands private limited liability company (“BV”) to a newly-incorporated Canadian subsidiary (“Newco”) under s. 85(1), following which BV is converted to a Dutch cooperative (“DC”), as a result of which all the shares of BV are cancelled and Holdco and Newco automatically become members of DC holding membership interests in proportion to their previous respective shareholdings. ... Rulings Including that Holdco and Newco are each considered to own shares of DC in the indicated respective proportions, and that s. 85.1(3) will apply to their respective drop-down transactions on the basis that they received treasury shares of DC. ...

Rulings that the merger will be considered an amalgamation (within the meaning of s. 87(1)) in the context of s. 87(11); and that pursuant to s. 87(2)(a), Amalco will be considered to have acquired each capital property of Target within the meaning of s. 87(11)(b). ...

Rulings that the merger will be considered an amalgamation (within the meaning of s. 87(1)) in the context of s. 87(11); and that pursuant to s. 87(2)(a), Amalco will be considered to have acquired each capital property of Target within the meaning of s. 87(11)(b). ...

CRA stated: [T]he Company's activities when considered as a whole are predominantly promoting and marketing the [credit card] program….Moreover, the services performed by the Company do not meet the factors that are used to determine whether a supply is arranging for a financial service under paragraph (l), such as the degree of direct involvement with the consumers or the time expended by the Company in the provision of a financial service referred to in any of paragraphs (a) to (i). Also the Company is not in the business of providing supplies of financial services or considered a financial intermediary…. ...

CRA stated that the business address of the recipient in Canada that is obtained by the supplier in the ordinary course of business that is the business address of the recipient from which the supplier is hired will be considered to be address that is most closely connected to the supply. Accordingly, the "business address" referred to above (e.g., of the human resources personnel who retained the Corporation) would be considered to determine the province in which the supply by the Corporation is made for purposes of s. 13(1). ...

Furthermore, a reduction in consideration is not considered to have occurred if the goods are sold back to the original supplier. To be considered a reduction of consideration, it must be evident that the goods are being returned to the supplier rather than being sold to the supplier. ...