Commercial Activity

Cases

Bowden v. Canada, [2011] GSTC 109, 2011 FCA 218

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398722 Alberta Ltd. v. Canada, [2000] FCJ No. 644 (CA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) 105

See Also

Klemen v. The Queen, 2014 DTC 1170 [at 3613], 2014 TCC 244

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) s. 165(5) cannot be used to increase an assessment 151
Tax Topics - Income Tax Act - Section 165 - Subsection 165(5) s. 165(5) cannot be used to increase an assessment 151
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment licensed equipment internally transferred in one-off transaction 176

Children's Clean Air Network Society v. The Queen, 2013 TCC 352 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 135 79

Sydney Mines Firemen's Club v. The Queen, [2011] GSTC 126, 2011 TCC 403

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Aviva Canada Inc. formerly CGU Group Canada Ltd. v. The Queen, 2006 TCC 57

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(2) - Paragraph 141.1(2)(a) purchase and immediate resale at the same FMV was not commercial activity 205
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business purchase and immediate resale at the same FMV was not an adventure 211
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Trademarks purchase and immediate resale at the same FMV was not an adventure 272

City of Regina v. The Queen, docket 1999-4570 (TCC)

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Administrative Policy

GST/HST Memorandum 21-2 “Residential Care Services” January 2019

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part IV - Section 2 meaning of disability, underprivileged, operated/single supply of residential care 374
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of residential care 55

13 April 2017 Interpretation 162819

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Office individual acting under a power of attorney is not engaged in commercial activity 119

10 February 2017 Ruling 162056

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Debt Security royalty agreement is not a debt security unless a minimum royalty is specified 238
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) the purchase of an IP royalty gives rise to non-creditable GST/HST to the investor 126
Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) buyout of royalty agreement not subject to s. 182 176

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 29

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 21. ("Interpretation of Commercial Activity")

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P-032, 20 July 1992

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P-167R

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GST M 400-1-2 "Documentary Requirements" under "Meals and Entertainment - Reimbursements"

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(5) 12

Guide for Providers of Financial Services under "Special Provisions" - "Distribution by Trust"

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Articles

Donald N. Cherniawsky, Christopher J. Sprysak, "Escaping the GST Net Through Use of Agency Law", Sales and Use Tax, Vol. IV, No. 2, p. 190.