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Note that if an employer resource is acquired by the employer for consumption or use in pension activities but not for supply to a pension entity, the deeming provisions of subsection 172.1(7) must be considered. ...

RULING REQUESTED You would like to know if the discount coupon redeemed by the customer on order [#1] is considered to be a reimbursable coupon for which [ACo] is entitled to claim an input tax credit (ITC) for the amount of the GST/HST that may be included in the value of the coupon. ...

In such circumstances, the employer would generally be considered to be making a supply of the relevant property or services to the plan trust, and sections 221, 225 and 228 would generally require a registrant employer to collect and remit GST/HST calculated on the consideration for the supply. ...

Consequently, the supply of the Pre-Pack display box would not be considered a “package” for the purposes of paragraph 168 of MS 4.3. ...

As you considered yourself self employed individuals, you reported the income received from the Funder as business income. 18. ...

As set out in GST/HST Memoranda Series 4.5.3 (4.5.3 Exports- Services and Intellectual Property), for purposes of section 23 of Part V of Schedule VI XXXXX, an advisory or consulting service is not considered to include any work that might be undertaken or performed as a result of the plans or recommendations accepted by the client or the advice provided by the client. ...

Accordingly, certain branch office expenses incurred outside Canada in respect of a Canadian activity that are allocated to a Canadian head office such as salaries, rent and entertainment expenses may be considered to be qualifying consideration after the application of the formula A-B in proposed subsection 217.1(1). ...

CRA Interpretation Bulletin IT-518 states that the following items are considered to be entertainment expenses and to be subject to the 50% limitation: (a) the cost of tickets for a theatre, concert, athletic event or other performance; (b) the cost of private boxes at sports facilities; (c) the cost of room rentals to provide entertainment, such as a hospitality suite; (d) the cost of a cruise; (e) the cost of admission to a fashion show; (f) the cost of entertaining guests at night clubs, athletic, social and sporting clubs and on hunting, fishing, vacation and similar trips. ...

As part of our review of the above noted ruling, we have also carefully considered and thoroughly reviewed the information and various documents provided by you including the following: • your letters of XXXXX; • the blank sample Finder's Fee Agreement (standard FFA); • the blank XXXXX including XXXXX and related correspondence to that placement; • various signed agreements between XXXXX and the following persons:- XXXXX- XXXXX- XXXXX- XXXXX- XXXXX- XXXXX- XXXXX- XXXXX- XXXXX; • a letter agreement issued by XXXXX confirming payment of a finder's fee to you XXXXX; • a letter from XXXXX referring to a payment of the finder's fee earned in connection with a recent private placement; • a list of XXXXX invoice numbers for finder's fees related to private placement offerings; and • various correspondences between you and certain corporations seeking financing through private placements (Issuers). ...

If a purchaser has control over the transporter and can change the destination of the delivery, the goods are not considered to be delivered by the vendor or the vendor's agent. ...