Section 217 - Definitions

Canadian Activity

Administrative Policy

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"

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Imported Taxable Supply

See Also

Reluxicorp Inc. v. The Queen, [2011] GSTC 138, 2011 TCC 336

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Administrative Policy

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 186 - Subsection 186(1) 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

Paragraph (a)

See Also

SLFI Group - Invesco Canada Ltd. v. The Queen, 2017 TCC 78, rev'd in part 2019 FCA 217

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (q) SPV funding MFT brokerage commissions was providing a GST-taxable management service 349
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply dominant element of service provided by financing SPV was financing 176

Paragraph (c)

Subparagraph (c)(ii)

Commentary

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Subparagraph (c)(iii)

Commentary

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Loading

Administrative Policy

GST/HST Notice 287 "CRA Administrative Positions on the Application of the Import Rules for Financial Institutions to Reinsurance Contracts" January 2015.

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Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"

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Qualifying Consideration

Administrative Policy

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"

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Articles

Michael Firth, Eric Reolon, "A Seven-Year (Retroactive) Plague on Cross-Border Reinsurance", Canadian GST Monitor, No. 283, April 2012, p.1: "Early experience has been that CRA will examine reinsurance [between a non-resident re-insurer and its Canadian affiliate] on a contract-by-contract basis, and identify loading content as anywhere between a third of the premium and its entire value."

Element A

Paragraph A(b)

Specified Derivative Supply

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 17

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