Subsection 171(1) - Person Becoming Registrant
Cases
Castle Building Group Ltd. v. Canada (National Revenue), 2021 FC 947
A parent corporation (“Castle”) made some of its taxable supplies of building materials to its wholly-owned subsidiary (“CBS”), which...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 156 - Subsection 156(4) - Paragraph 156(4)(b) - Subparagraph 156(4)(b)(ii) | it was not unreasonable of CRA to refuse a late ETA s. 156 election based on a corporation’s failing to file nil returns | 558 |
0741508 B.C. Ltd. and 0768723 B.C. Ltd. (Re), 2014 BCSC 1791
In 2011, the petitioners conveyed undeveloped B.C. lands to a limited partnership. In 2013, CRA assessed the petitioners for their failure to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Rectification & Rescission | failure to file timely tax returns did not invoke the dirty hands bar to equitable rescission | 363 |
Administrative Policy
26 February 2015 CBA Roundtable, Q. 16
Company B transfers its co-ownership interest in a commercial rental property on a rollover basis to Company C, whose sole activity is to hold the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) | backdated registration of unregistered purchaser of commercial real estate | 542 |
15 November 2011 Headquarters Letter Case No. 135608
Where a "capital pool company" which has raised capital pursuant to a prospectus on a blind pool basis has identified an acquisition of assets...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a) | 140 | |
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) | 41 | |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) | commencement of preliminary commercial activity | 140 |
1996 Corporate Management Tax Conference Round Table, Q. 11
Where a person does not register prior to acquiring a business, it will be subject to s. 171 upon becoming a registrant.
Subsection 171(3)
See Also
Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure)
The appellant, which had been operating a Boston Pizza restaurant on leased premises since 2008, was ordered by the new owner of the land to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) | winding-down operations qualified a de-registrant as a “registrant”/registration retroactive | 212 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Registrant | registrant based on wind-up activities | 62 |
| Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a) | holding discontinued equipment | 151 |
Subsection 171(3)
Administrative Policy
GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017
Application to public service body
58. Where, at any time in a claim period, a PSB ceases to be a GST/HST registrant, the PSB is deemed under...
Paragraph 171(4)(b)
Administrative Policy
GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017
57. ...
Example 11 – Adjustment to net tax for rental property on becoming a small supplier division
In July, a registrant PSB resident in...