Subsection 170(1))
Paragraph 170(1)(b)
Subparagraph 170(1)(b)(ii)
Cases
Westcoast Energy Inc. v. Canada, 2022 FCA 57
Westcoast reimbursed employees who had incurred various taxable health care services, e.g., acupuncture, massage therapy and naturopathy. and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) - Paragraph 175(1)(b) | health care services rendered to employees were not in relation to the employer’s activities | 226 |
See Also
Westcoast Energy Inc. v. The Queen, 2020 TCC 116 (Informal Procedure), aff'd 2022 FCA 57
Westcoast reimbursed (through Manulife as its agent) employees who had incurred various health care services. As a preliminary matter, Sommerfeldt...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) - Paragraph 175(1)(b) | an employer was not entitled to ITCs for the GST/HST on reimbursed employee health care services | 472 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | employees rather than employer were the recipients of health care services even where the employer paid the health care provider directly | 331 |
Paragraph 170(1)(c)
Administrative Policy
21 May 2014 CBA Roundtable, Q.23
The registrant acquired personal property strictly for personal use, free of charge, by an employee or shareholder.
CRA indicated that if the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 173 - Subsection 173(1) - Paragraph 173(1)(c) | s. 173(1)(c) deemed commercial use does not prevail over s. 170(1)(c) ITC denial and causes subsequent sale to be taxable | 133 |
18 April 2002 GST/HST Interpretation 35471 - Taxable Benefits and Input Tax Credit Entitlements
In rejecting the propositions advanced that, where a registrant has calculated a taxable benefit under s. 173 for goods and services provided to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 173 - Subsection 173(1) - Paragraph 173(1)(c) | no requirement to report tax on s. 173(1) deemed supply if an ITC is denied under s. 170(1)(b) or (c) | 185 |
Subsection 170(2) - Further Restriction
Administrative Policy
5 January 2016 External T.I. 2015-0622991E5 - Reasonableness of intercorporate management fees
Will CRA revisit its position on the reasonableness of management fees paid by an operating company to a holding company that is owned by an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 67 | reasonableness of management fee paid by opco to management holdco following 6051944 | 183 |
6051944 Canada Inc. The Queen, 2015 CCI 180, 2015 TTC 180
The appellant, which engaged in a home construction business, paid management fees to its two shareholders, which were companies whose sole...