See Also
Athabasca University v. The Queen, 2016 TCC 252
Athabasca University, which provided online courses to its students and delivered printed books to them without any additional charge, was...
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 259.1 - Subsection 259.1(2) | University’s purpose in acquiring books for its students was their education rather than the (free) “sale” of the books to them | 277 |
| Tax Topics - Statutory Interpretation - Technical Notes | Explanatory Notes not followed | 120 |
Administrative Policy
28 February 2019 CBA Roundtable, Q.27
ETA s. 254(4)(a) and the Ontario equivalent required that in order for a taxable supply by a builder of a new house or condo unit to generate the...
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| Tax Topics - Excise Tax Act - Section 254 - Subsection 254(4) - Paragraph 254(4)(a) | legal title can pass directly from the developer to the builder’s individual purchaser | 557 |
22 August 2013 Interpretation 150985
Before going on to find that the assignment by an individual of a sub-leasehold interest in a recreational vehicle site would be exempt under...
31 October 2011 Ruling Case No. 136392
The granting of easements in consideration for a single lump sum payment was ruled to be a supply of real property by way of sale even though...
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| Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | 43 |
29 July 2011 Headquarters Letter Case No. 122272r
In order to finance the purchase of a new condo from a builder, an individual (the "Purchaser") enters into a "Declining Partnership Agreement,"...
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | 157 |
3 November 2009 GST/HST Interpretation 109447 - Lease Surrender
The surrender of a lease to the landlord qualified as a demise of real property, so that s. 221(2)(b) and 228(4) applied to the consideration...
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| Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | surrender of realty lease is transfer of realty | 31 |
GST/HST Policy Statement P-111R, The Meaning of Sale with respect to Real Property, February 1995
Transfer of ownership need not be pursuant to a sale agreement (e.g., a demise by will)
C. Application of Agreement to Transfer Ownership
For...
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| Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | 182 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Real Property | 179 |
18 January 1995 Headquarters Letter No. 11634-2
After referring with aproval to Lubbock Fine, CRA stated that "a lease surrender is a sale" so that a lease surrender payment would constitute...
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Real Property | leasehold interest is real property | 49 |
GST/HST Policy Statement P-174, Emphyteutic Leases, 31 March 1995
Essentially, an emphyteutic lease is a lease whereby the emphyteutic lessor permits an emphyteutic lessee to use the land (and any immovables on...