See Also
Club Intrawest v. The Queen, 2016 TCC 149
The members of the Appellant (which was a non-share Delaware corporation resident in Canada) included Canadian and U.S.-resident individuals who...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent | 377 |
| 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) - 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 |
Customs and Excise Commissioners v. High Street Vouchers Ltd., [1990] BTC 5092 (Q.B.D.)
The taxpayer sold vouchers to retailers at a discount of approximately 9% from their face value, and agreed with the retailers to accept the...
Administrative Policy
11 March 2016 Excise and GST/HST News - No. 98
CRA has developed a list of factors that are generally present when an on-line supply by a school authority is a “service of instructing,”...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - 8 | distinction between on-line supply of “service of instructing” v. supply of “intangible personal property.” | 261 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Place of Amusement | status of a location as a “place of amusement” for purposes of the public sector body exemption may be determined on an event by event basis | 341 |
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part V.1 - 1 - Paragraph 1(e) | “place of amusement” may be determined on an event by event basis | 154 |
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ("Assumption of ‘Under Water' Contract")
A GST-registered Vendor sells resource properties to a GST-registered Purchaser, and Purchaser agrees to assume long-term contracts ("Assumed...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 152 - Subsection 152(3) | 105 |
18 February 2004 Headquarters Letter RITS 46264
A discussion of the distinction between a supply of an admission and a supply of a service of instruction. (The issue initially was raised in the...
Technical Information Bulletin B-090 "GST/HST and Electronic Commerce" July 2002
Discussion of distinction between supplies of services and intangible personal property including:
Factors that generally indicate that a supply...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g) | 55 |
12 July 1995 Ruling File No. 11755-20
"A Tenant inducement is interpreted as being consideration for the supply of a service which occurs at the time the lease is signed.
Paragraph (c)
See Also
Key Property Management Corporation v. The Queen, 2004 TCC 210
The Appellant (“Key”) provided the services of its employees to 30 or more affiliated owners of rental properties and remitted all the source...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | maintenance employees working for indeterminate group companies were not hired as agent for those companies | 174 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | documentary requirements mandatory | 105 |
Administrative Policy
15 May 2012 Ruling Case No. 142436
Company A, which is the parent of Company B and C, will hire, remunerate and manage employees on its own behalf and in an agency capacity for its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 |
| Tax Topics - General Concepts - Agency | parent bearing payroll and source deductions for itself and subs | 48 |