Agency

Table of Contents

Commentary

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Cases

J.D. Irving Limited v. Agence du revenu du Québec, 2020 QCCQ 2423

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Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) property serviced by the user was not a leasing property 410

Canada v. Ngai, 2019 FCA 181

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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(g) co-purchasing aunt of the nephew occupant could not claim the rebate 441
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 6 - Subsection 6(1) - Paragraph 6(1)(h) cryptic Crown pleading cured by opportunity for additional written submissions 153

Club Intrawest v. Canada, 2017 FCA 151

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Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) supplies of services re cross-border vacation home portfolio split into domestic and foreign supplies 634
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply service in relation to a cross-border vacation home portfolio split into two (GST-taxable and non-taxable) geographic components 435

Felty v. Ernst & Young LLP, 2015 BCCA 445

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Tax Topics - General Concepts - Negligence, Fiduciary Duty and Fault accounting firm exclusion clause was binding 203

Public Television Association of Quebec v. Canada (National Revenue), 2015 FCA 170

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Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Charitable Foundation appellant failed to control its alleged agent (a US public television station) and was its conduit 206

Canada v. Merchant Law Group, 2010 FCA 206

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient law firm did not incur disbursements as agent for its clients 71

Canada v. 1524994 Ontario Limited, 2007 FCA 74

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply agreements respected for supply determination purposes 215
Tax Topics - General Concepts - Evidence agreement intended to deceive government 216

Canada v. Libra Transport (BC) Ltd., [2001] GSTC 57, Docket: 98-2151-GST-G, aff’d 2002 FCA 347

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply trucker presumed not to be an unlicensed insurer 242
Tax Topics - General Concepts - Illegality trucker presumed not to be an unlicensed insurer 56

Vanex Truck Service Ltd. v. Canada, 2001 FCA 159

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply charges to fleet operators for insurance and licences were taxable resupplies 302

Colbert v. The Queen, 94 DTC 6620, [1994] 2 CTC 345 (FCTD)

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Wharton v. The Queen, 92 DTC 6582, [1993] 1 CTC 10 (FCTD)

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Alberta Gas Ethylene Co. Ltd. v. The Queen, 90 DTC 6419, [1990] 2 CTC 171 (FCA)

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Doyle v. MNR, 89 DTC 5483, [1989] 2 CTC 270 (FCTD)

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London Life Insurance Co. v. The Queen, 87 DTC 5312, [1987] 2 CTC 90 (FCTD), aff'd 90 DTC 6001 (FCA)

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E.S.G. Holdings Ltd. v. The Queen, 76 DTC 6158, [1976] CTC 295 (FCA)

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The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)

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Simard-Beaudry Inc. v. M.N.R., 74 DTC 6552, [1974] CTC 715 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham motives should not be exaggerated 98
Tax Topics - General Concepts - Tax Avoidance motives should not be exaggerated 98
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost of option included in cost of acquired asset 28
Tax Topics - Income Tax Act - Section 245 - Old 134

Denison Mines Ltd. v. MNR, 71 DTC 5375 (FCTD), aff'd 72 DTC 6444 (FCA), aff'd 74 DTC 6525 (SCC)

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United Geophysical Co. of Canada v. MNR, 61 DTC 1099 (Ex Ct)

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Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) U.S. equipment rentals not attributable to Canadian services 137
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) "rent" can be for personalty 106

See Also

Andre Lamy Medicine Professional Corporation v. The Queen, 2020 TCC 61

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Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Expenditure - Paragraph (a) a surgeon carried out his cardiac SR&ED on behalf of his professional corporation 258
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) surgeon carried out his research qua employee of his professional corporation 179

Lohas Farm Inc. v. The Queen, 2019 TCC 197

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Tax Topics - General Concepts - Onus no burden of displacing an assumption as to a factual matter which the taxpayer could not be reasonably expected to know 286
Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(c) - Subparagraph 3(c)(ii) missing names in receipts issued by vendor were cured by memo maintained by the purchaser 205
Tax Topics - Excise Tax Act - Section 169 purchases were made as agent for grey market registrant 278

Anand v. The Queen, 2019 TCC 119

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Words and Phrases
agency
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Tax Topics - General Concepts - Evidence inconsistencies in written contract were patent ambiguity permitting parol evidence 393

Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration consideration for temps included their remuneration 294

Laval Technopole v. Agence du revenu du Québec, 2018 QCCQ 6352

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Fully exempt interest - Paragraph (a) - Subparagraph (a)(iii) traditional common law tests of Crown agency applied in determining whether companies were agents of Canadian municipalities 282
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(c) municipally influenced companies were agents of the municipality 82

Jayco, Inc. v. The Queen, 2018 TCC 34

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Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) under the UCC goods were delivered by a U.S. manufacturer outside Canada/”symbolical” delivery can occur under a bill of lading 595
Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) - Paragraph 306.1(1)(a) issue of multiple supplies not raised in Notice of Objection (or Notice of Appeal) 155

Lewski v Commissioner of Taxation, [2017] FCAFC 145

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense obligation to pay purchase price was incurred on agreement date rather than subsequent closing 430
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) an alternate resolution that the taxpayer was not entitled to an income distribution if Revenue denied a trust deduction made her entitlement contingent and non-includible 374
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) since the taxpayer through her husband as agent had knowledge of an income distribution, her subsequent purported disclaimer was not immediate 304
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) a trust income declaration that was subject to a tax contingency did not result in an income inclusion to the beneficiary 149

Zheng v. The Queen, 2017 TCC 132 (Informal Procedure)

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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) rebate form was signed and completed in the name of an individual who was acting as agent 483
Tax Topics - Excise Tax Act - Section 279 rebate application made and signed as agent 78

572256 Ontario Limited v. The Queen, 2017 TCC 108 (Informal Procedure)

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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) property acquired and maintained as agent for registrant 169

Persepolis Contracting Inc. v. The Queen, 2017 TCC 89 (Informal Procedure)

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply no evidence of implicit acceptance of agency 87

GEM Health Care Group Limited v. The Queen, 2017 TCC 13

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Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) no barter of management services for HST purposes between two affiliates employing the same key manager 330
Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) issuance of credit note is mandatory for ITC claim 165
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient no barter of managment services between affiliates/construction supplies acquired by parent as agent for owner-subs 196

Cheema v. The Queen, 2016 TCC 251 (Informal Procedure), rev'd 2018 FCA 45

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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) unrelated individual acquiring interest as bare trustee did not deny the rebate 295

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

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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) - Service payment of condo operating expenses was a service 211
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

SNF L.P. v. The Queen, 2016 TCC 12

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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) ITCs where reasonable efforts to verify suppliers and registration numbers, where GST not remitted 402
Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 2 - Intermediary intermediary need not carry on business and may be a nominee 131
Tax Topics - Excise Tax Act - Section 261 - Subsection 261(1) no rebate entitlement for an error caused by the applicant’s own inattention and carelessness 114

McLarty v. The Queen, 2014 DTC 1162 [at 3556], 2014 TCC 30

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Tax Topics - General Concepts - Illegality participations contrary to agreement were disregarded 113
Tax Topics - General Concepts - Sham sham cannot apply to just part of transaction 145
Tax Topics - General Concepts - Tax Avoidance sham cannot apply to just part of transaction 145
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) revenues 10% of interest 186
Tax Topics - Income Tax Act - Section 67 leveraged purchase of seismic data at arm's length was presumptively reasonable 296

2253787 Ontario Inc. v. The Queen, 2014 TCC 121 (Informal Procedure)

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Commissioners for HM Revenue and Customs v. Secret Hotels2 Ltd., [2014] UKSC 16

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Tax Topics - General Concepts - Substance characterize before attaching label 291

9101-2310 Québec Inc. v. The Queen, 2013 DTC 1136 [at 711], 2012 TCC 365, rev'd 2013 FCA 241

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SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181

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Velcro Canada Inc. v. The Queen, 2012 DTC 1100 [at 2966], 2012 TCC 57

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Tax Topics - Treaties - Income Tax Conventions - Article 12 268

Fourney v. The Queen, 2012 DTC 1019 [at 2575], 2011 TCC 520

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Tax Topics - General Concepts - Corporate/Separate Personality 257
Tax Topics - General Concepts - Ownership presumption of resulting trust where property transfer for no consideration 257
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) bare trust arising on creditor-proofing transfer 257
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) line codes in electronic filings were incomprehensible to taxpayer 300
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition rebuttable presumption of resulting trust on transfer for no consideration 257

SLM Direct Marketing Ltd. v. The Queen, 2007 TCC 415 (Informal Procedure)

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Y S I's Yacht Sales International Ltd v. The Queen, 2007 TCC 306

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Arpeg Holdings Ltd v. The Queen, 2007 DTC 131, 2006 TCC 593

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Royal Winnipeg Ballet v. Canada (Minister of National Revenue), 2006 DTC 6323, 2006 FCA 87

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 97

Calce Holdings Ltd. v. The Queen, 2005 DTC 959, 2005 TCC 335

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Tax Topics - General Concepts - Price Adjustment Clause 57

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

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service - Paragraph (c) maintenance employees working for indeterminate group companies were not their employees 259
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) documentary requirements mandatory 105

Drug Trading Company Ltd. v. The Queen, [2001] GSTC 48 (TCC) (Informal Procedure)

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Skylink Voyages Inc. v. The Queen, [1999] GSTC 119 (TCC)

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Continental Bank of Canada v. The Queen, 94 DTC 1858, [1995] 1 CTC 2135 (TCC), aff'd at 98 DTC 6501 (SCC) after being, rev'd 96 DTC 6355 (FCA)

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C&E Commissioners v. Music and Video Exchange Ltd., [1992] BTC 5028 (Q.B.)

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Tax Topics - General Concepts - Tax Avoidance tax minimization acceptable 78

Ingram v. MNR, 91 DTC 939, [1991] 2 CTC 2259 (TCC)

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T. Eaton Co. v. Minister of Revenue, [1989] 1 CTC 269 (Ont CA)

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Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD)

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Trident Holdings Ltd. v. Danand Investments Ltd. (1988), 64 OR (2d) 65 (Ont CA)

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Customs and Excise Commissioners v. Tarmac Roadstone Holdings Ltd., [1987] BTC 5074 (C.A.)

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Administrative Policy

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage December 2020

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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 962
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) 59

28 February 2019 CBA Roundtable, Q.12

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Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) an adjustment for municipal taxes and the assignment of tenant leases form part of a single supply of a sale of an office tower 329

18 October 2017 Ruling 173963r

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Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 18 members of the profession did not require membership in the Association to provide their services 218

25 February 2016 CBA Roundtable, Q. 7

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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 - 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) - Service dentists jointly employ staff so as to avoid GST 296
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Taxable Supply dentists jointly employ staff so as to avoid GST 203

14 October 2016 Interpretation 170549

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Tax Topics - Excise Tax Act - Section 273 - Subsection 273(1) Westcan test for JV, co-tenancy was JV 176
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) nominee accepted as registrant 156
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) agent could not claim ITCs 157

GST/HST Notice 284 "Bare Trusts, Nominee Corporations and Joint Ventures" February 2014

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Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1.1) agent not entitled to ITCs 113
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) taxable supply of nominee services 63
Tax Topics - Excise Tax Act - Section 273 - Subsection 273(1) administrative tolerance for nominee operators 197

3 January 2014 External T.I. 2013-0507541E5 F - Crowdfunding

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15 May 2012 Ruling Case No. 142436

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service - Paragraph (c) employees with one source-deduction account with parent treated as jointly-employed for GST purposes 256
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

Interpretation Revenu Québec TVQ. 16-30/R1 "Nominee Agreements" 9 December 2011

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14 June 2010 Internal T.I. 2010-0366611I7 F - Determination of CCPC Status

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Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) sole beneficiary of a trust did not have a s. 251(5)(b) right to trust shares 44
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b) agreement was not a USA since it did not contain an outright transfer of the powers of the directors to the shareholders 549
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) non-resident shareholder with 60%+ economic interest, extensive veto rights and responsibility for future funding of R&D work had de facto control 457

GST/HST Info Sheet GI-012, Agents, November 2005

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Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1) 237

25 February 2005 Ruling Case No. 51031

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Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1) 30

GST/HST Technical Information Bulletin B-068 "Bare Trusts" Amended 10 January 2005

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) 52
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) bare trustee required to register if it charges fees 58
Tax Topics - Excise Tax Act - Section 269 transfer of registered title by (or to) bare trustee generally is for nil consideration 102

P-182R "Acting as an Agent" July 2003

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10 January 2001 External T.I. 2000-0056135 - REPORTING TAXABLE BENEFITS

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) agent may fulfill employer's source deduction obligations 145

16 April 1997 Internal T.I. 9705717 - BENEFICIAL OWNER OF PROPERTY

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 23

4 April 1995 External T.I. 9506985 - AGENCY AGREEMENT

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P-0016 “Acting as an Agent” 3 April 1992

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IT-216 "Corporation Holding Property as Agent for Shareholder"

Articles

Emmanuel Sala, Judith Lemieux, "The Impact of Quebec Civil Law on the Recognition of Mandator-Mandatary Relationships by Quebec and Canadian Tax Authorities", Tax Topics (Wolters Kluwer), No. 2375, 14 November 2017, p. 1

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Brent Murray, "Cost-Sharing, Agency & Resupply Agreements: the When and the Why", Canadian GST/HST Monitor (Wolters Kluwer), No. 329, February 2016, p.1

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John G. Bassindale, Robert G. Kreklewetz, "Undisclosed Agency Questioned", Canadian Tax Highlights", Vol. 22, No.7, July 2014, p.4

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Ewens, "Risk of Challenge Based on Allegation of Agency", Corporate Structures and Groups, Vol. IV, No. 1, 1996, p. 184.

Bies, "Agency and Canadian Income Tax Law", 1982 Conference Report, p. 927.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 0