Subsection 186(1) - Related Corporations
See Also
Miedzi Copper Corporation v. The Queen, 2015 TCC 26 (Informal Procedure)
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Pay Linx Financial Corporation v. The Queen, 2011 TCC 203 (Informal Procedure)
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Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) | "acquisition" of shares includes cancellation of those shares on a Delaware merger; "in relation to" to be construed broadly | 305 |
Perfection Dairy Group Limited v. The Queen, 2008 TCC 342 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | fees were incurred in relation to claim of bankrupt subsidiary rather than to earn consulting fees | 152 |
Administrative Policy
8 March 2018 CBA Commodity Tax Roundtable, Q.14
23 November 2016 Interpretation 165129
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | expenses incurred respecting a subsidiary unit trust are ineligible for ITCs unless incurred as management-services inputs | 161 |
GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017
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May 2016 Alberta CPA Roundtable, GST Q.14
26 February 2015 CBA Roundtable, Q.21
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 156 - Subsection 156(1) - Qualifying Member | s. 186(1) does not deem use of property in commercial activity | 58 |
26 February 2015 CBA Roundtable, Q. 17
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 34
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 217 - Imported Taxable Supply | failure to self-assess under s. 218 where satisfy s. 186(1) | 61 |
| Tax Topics - Excise Tax Act - Section 281.1 - Subsection 281.1(1) | failure to self-assess under s. 218 where satisfy s. 186(1) | 61 |
27 March 2009 Interpretation 106684
P-196R "Whether Administrative Overhead Costs Fall Under Subsection 186(1) of the Excise Tax Act", August 10, 2007.
29 November 2004 Interpretation 54669
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(4) | Holdco eligible for ITCs on inputs used by it to make free supplies to Opco | 214 |
GST M 700-5-6 "Input Tax Credits for Holding Companies, Takeovers, and Multi-Tiered Corporations"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) | 0 |
Articles
Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax, Federated Press, Volume XIII, No. 2, 2015, p. 674.
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Subsection 186(2) - Takeover Fees
See Also
Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) | listing fees to issue shares to target shareholders were eligible | 255 |
Administrative Policy
15 November 2011 Headquarters Letter Case No. 135608
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| 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 171 - Subsection 171(1) | 124 | |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) | commencement of preliminary commercial activity | 140 |
GST M 700-5-6 "Input Tax Credits for Holding Companies, Takeovers, and Multi-Tiered Corporations"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) | 0 |