Service

See Also

Canadian Imperial Bank of Commerce v. The Queen, 2019 TCC 79, aff'd 2021 FCA 96

Under an agreement between the appellant (CIBC) and Aeroplan, as the successor to Air Canada (“AC”) (the “Agreement”), Aeroplan agreed to...

The text of this content is paywalled except for the first five days 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) - Supply Aeroplan points program occurred as single supply 264
Tax Topics - Excise Tax Act - Section 181.2 Aeroplan Miles were not gift certificates as they had no stated monetary value 193
Tax Topics - Excise Tax Act - Section 138 supply of Aeroplan Miles was ancillary to promotional services 370

Stewardship Ontario v. The Queen, 2018 TCC 59

Stewardship Ontario (“SO”) was a not-for-profit corporation that operated, as part of a regime governed by the Waste Diversion Act, 2002...

The text of this content is paywalled except for the first five days 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) - Supply performance of a statutory duty can nonetheless by a supply 279
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration statutorily-mandated waste recycling charges were consideration for a taxable supply 278
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) statutory object of avoiding tax cascading 397
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient those subject to statutory user charges were "recipients" 201

Revenue and Customs Commissioners v. Findmypast Ltd., [2017] CSIH 59

Findmypast carried on the business of providing access to genealogical and ancestry websites which it owned or in respect of which it held a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis prior cases reviewed for principles rather than similar facts 96
Tax Topics - Excise Tax Act - Section 152 - Subsection 152(1) the time of a supply of services was accelerated by prepayment only where the services were precisely identifiable 829
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(6) precise services to be purchased with credits were not yet identified 156

Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151

The members of the Appellant (which was a non-share Delaware corporation resident in Canada) included Canadian and U.S.-resident individuals who...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent 377
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) s. 142(1)(d) only applies to a supply exclusively re real property 632
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of covering all time share operating costs 172
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) GST collectible based on invoicing times 79
Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) objecting to quantum was sufficient particularity 177
Tax Topics - General Concepts - Ownership beneficial owner did not transfer property risk 183
Tax Topics - General Concepts - Evidence foreign law assumed the same 101

Customs and Excise Commissioners v. High Street Vouchers Ltd., [1990] BTC 5092 (Q.B.D.)

The taxpayer sold vouchers to retailers at a discount of approximately 9% from their face value, and agreed with the retailers to accept the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Administrative Policy

Excise and GST/HST News - No. 101 March 2017

A medical facility may pay a doctor set fees for agreeing to be on call for specified periods. CRA considers that such fees are not medical...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

11 March 2016 Excise and GST/HST News - No. 98

CRA has developed a list of factors that are generally present when an on-line supply by a school authority is a “service of instructing,”...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 8 distinction between on-line supply of “service of instructing” v. supply of “intangible personal property.” 261
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Place of Amusement status of a location as a “place of amusement” for purposes of the public sector body exemption may be determined on an event by event basis 341
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part V.1 - Section 1 - Paragraph 1(e) “place of amusement” may be determined on an event by event basis 154

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ("Assumption of ‘Under Water' Contract")

A GST-registered Vendor sells resource properties to a GST-registered Purchaser, and Purchaser agrees to assume long-term contracts ("Assumed...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 152 - Subsection 152(3) 111

18 February 2004 Headquarters Letter RITS 46264

A discussion of the distinction between a supply of an admission and a supply of a service of instruction. (The issue initially was raised in the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Technical Information Bulletin B-090 "GST/HST and Electronic Commerce" July 2002

Discussion of distinction between supplies of services and intangible personal property including:

Factors that generally indicate that a supply...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

12 July 1995 Ruling File No. 11755-20

"A Tenant inducement is interpreted as being consideration for the supply of a service which occurs at the time the lease is signed.

Paragraph (c)

See Also

Key Property Management Corporation v. The Queen, 2004 TCC 210

The Appellant (“Key”) provided the services of its employees to 30 or more affiliated owners of rental properties and remitted all the source...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency maintenance employees working for indeterminate group companies were not hired as agent for those companies 174
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) documentary requirements mandatory 105

Administrative Policy

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021

[Q.3-9] Pro rata recognition of payroll under a cost-sharing agency arrangement

  • CRA will recognize employee cost sharing arrangements where, for...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(9) - Paragraph 125.7(9)(a) 150
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Entity - Paragraph (c) - Subparagraph (c)(ii) 236
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(d) 725
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(a) 401
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(b) 367
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Employee 637
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Remuneration 474
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(2) - Element B 245
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue 1009
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Entity - Paragraph (f) 79
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Entity - Paragraph (a) 236
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Entity - Paragraph (d) - Subparagraph (d)(ii) 170
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(9) - Paragraph 125.7(9)(b) 379
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(g.5) 198
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4.1) 194
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Top-Up Percentage 333
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Base Percentage 175
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Baseline Remuneration 267
Tax Topics - Income Tax Act - Section 241 - Subsection 241(3.5) 76
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) 141
Tax Topics - General Concepts - Agency 92
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Executive Compensation Repayment Amount 102

25 February 2016 CBA Roundtable, Q. 7

A group of dentists, who are not in partnership, wish to share the costs of staff such as receptionists and bookkeepers and also are shared...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 arrangement for sharing employees not a partnership in Quebec or ROC/profit-sharing arrangement required 234
Tax Topics - General Concepts - Agency dentist handles source deductions and payroll as agent for colleagues 127
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) joint responsibility of joint employers 434
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Taxable Supply dentists jointly employ staff so as to avoid GST 203

15 May 2012 GST/HST Ruling 142436 - Implementation of Cost Sharing Arrangement

Company A, which is the parent of Company B and C, will hire, remunerate and manage employees on its own behalf and in an agency capacity for its...

The text of this content is paywalled except for the first five days 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) - Supply employees with one source-deduction account with parent treated as jointly-employed for GST purposes 187
Tax Topics - General Concepts - Agency parent bearing payroll and source deductions for itself and subs 48