News & Analysis as of

Tax Liability Goods and Services Tax

Shumaker, Loop & Kendrick, LLP

The Estate Planner, March/April 2025

Now’s the time to review your GST tax exposure Absent congressional action this year, the federal gift and estate exemption and the generation-skipping transfer (GST) tax exemption (currently $13.99 million) are scheduled...more

Stikeman Elliott LLP

GST/HST Input Tax Credits for Dentists: Canada Revenue Agency Revokes Administrative Arrangement

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New GST/HST Notice 339, published on October 25, 2024, provides that as of the first day of the fiscal year that begins on or after January 1, 2025, dentists will no longer be able to claim GST/HST input tax credits (“ITCs”)...more

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Tax Court’s Denial of a Bank’s GST/HST Rebate Claims Affirmed; No Issue Estoppel as Retroactive GST/HST Legislation Had Been...

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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

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New GST/HST Notice on Services Provided by Insurance Intermediaries

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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

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Credit Card Rewards Program Expenses: Tax Court of Canada Doesn’t Buy $13.97 Million GST/HST Input Tax Credit Claim

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On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more

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Federal Court of Appeal Confirms Tax Court of Canada’s Decision: Supply of Right to Place and Operate ATMs is a Taxable Supply

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On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more

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Court of Appeal of Québec Confirms Restrictions on the Tax Authorities’ Ability to Set Off Certain Claims in Insolvency...

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On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more

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Dental Crowns and GST/HST Credits: A Dentist Wants to Have His Cake and Eat it Too

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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

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GST/HST Elections: Why Being Late Is Not Always Fashionable (Cont’d)

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On December 6, 2021, the Federal Court of Appeal (“FCA”) affirmed the Federal Court’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue), which had dismissed the taxpayers’ application for judicial...more

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