See Also
Casa Blanca Homes Ltd. v. The Queen, 2013 TCC 338 (Informal Procedure)
The appellant bought and resold the right and obligation to acquire lots from a land developer. Hogan J found that the "non-refundable" deposits...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | possible to structure separate assignments | 266 |
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 18
In 112274, CRA concluded that the assignment of an instalment contract did not constitute a financial service. Has CRA changed its view from...
GST Memorandum (New Series), 17.1, para. 8
"'Debt Security' does not include a contingent right."
April 1999 GST Memorandum (New Series), 17.1
A "debt security" does not include an amount whose payment is conditional upon the occurrence or non-occurrence of some future event that may...
5 December 2003 Interpretation 44874
Lessor enters into equipment leases (the "Asset Leases") with users of the equipment (the "Asset Lessees"), who also have options to purchase the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 136 - Subsection 136(1) | concurrent lease qualified as lease | 202 |
3 September 1997 Ruling HQR0000579
"A swap transaction falls under the definition of 'debt security' since the definition of debt security... includes 'a right to be paid money'."
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 151 |
P-170 "Debt Security and Contingent Amounts"
A debt security does not include a contingent right.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Instrument | 49 |