Subsection 170(1))
Paragraph 170(1)(b)
Subparagraph 170(1)(b)(ii)
Cases
Westcoast Energy Inc. v. Canada, 2022 FCA 57
Westcoast reimbursed employees who had incurred various taxable health care services, e.g., acupuncture, massage therapy and naturopathy. and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) - Paragraph 175(1)(b) | health care services rendered to employees were not in relation to the employer’s activities | 226 |
See Also
Westcoast Energy Inc. v. The Queen, 2020 TCC 116 (Informal Procedure), aff'd 2022 FCA 57
Westcoast reimbursed (through Manulife as its agent) employees who had incurred various health care services. As a preliminary matter, Sommerfeldt...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) - Paragraph 175(1)(b) | an employer was not entitled to ITCs for the GST/HST on reimbursed employee health care services | 472 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | employees rather than employer were the recipients of health care services even where the employer paid the health care provider directly | 331 |
Subsection 170(2) - Further Restriction
Administrative Policy
5 January 2016 External T.I. 2015-0622991E5 - Reasonableness of intercorporate management fees
Will CRA revisit its position on the reasonableness of management fees paid by an operating company to a holding company that is owned by an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 67 | reasonableness of management fee paid by opco to management holdco following 6051944 | 183 |
6051944 Canada Inc. The Queen, 2015 CCI 180, 2015 TTC 180
The appellant, which engaged in a home construction business, paid management fees to its two shareholders, which were companies whose sole...