Debt Security

Table of Contents

Cases

2441-0946 Québec Inc. (c.b.a., Insta-chèques) v. Agence du revenu du Québec, 2017 QCCA 1491

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(a) - Subparagraph 149(1)(a)(iii) company in a cheque-cashing business was a "dealer in … financial instruments" 251

See Also

Casa Blanca Homes Ltd. v. The Queen, 2013 TCC 338 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
deposit
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply possible to structure separate assignments 252

Administrative Policy

23 April 2019 GST/HST Ruling 186334 - S AND INTERPRETATIONS - Annual licensing fees and public service bodies’ rebate eligibility

An incorporated non-profit organization (the “Organization”), being a provincial professional society makes NSF cheque charges. CRA stated:

With respect to the insufficient funds fee, a dishonoured cheque triggers a situation in which the [Organization] obtains a “right to be paid money” by the drawer of the cheque. This “right to be paid” meets the definition of “debt security” in subsection 123(1). The debt security is a “financial instrument” and the processing of a financial instrument is an exempt supply of a “financial service” … .

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 law society was an “other body established by a government” 57
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 - Paragraph 20(c) consideration for licensing included expired licence fees 43
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 20 - Paragraph 20(b) - Subparagraph 20(b)(i) exempt processing and registration fees of professional society 62
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 6 jurisprudence exam fee exempt, but not charge for processing exam administered by another body 144

24 January 2018 Ruling 156434

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) separately stated originating fee for sourcing credit agreement was part of consideration for its assignment 195

10 February 2017 Ruling 162056

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
contingent right
Locations of other summaries Wordcount
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
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity receipt of royalty not considertion for a taxable supply 117

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 December 2003 Interpretation 44874

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 136 - Subsection 136(1) concurrent lease qualified as lease 202

April 1999 GST Memorandum (New Series), 17.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 September 1997 Ruling HQR0000579

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1 December 1994 P-170 "Debt Security and Contingent Amounts"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.