This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more
In July 2023, the Canada Revenue Agency (“CRA”) released GST/HST Notice 325 (the “Notice”) with respect to services provided by certain insurance intermediaries. The Notice essentially makes official the 180-degree turn the...more
9/7/2023
/ Canada ,
Canada Revenue Agency (CRA) ,
Future Tax Treatment ,
Goods or Services ,
GST ,
Insurance Agents ,
Intermediaries ,
International Tax Issues ,
Sales Commissions ,
Tax Liability ,
TPAs
In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...more
On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more
On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more
6/30/2022
/ Appeals ,
Automotive Industry ,
Canada ,
Canada Revenue Agency (CRA) ,
Commercial Leases ,
GST ,
Input Tax Credits ,
International Tax Issues ,
Securitization ,
Supporting Documentation ,
Tax Court ,
Tax Credits ,
Tax Planning ,
Tax Reform