Cases
Calgary (City) v. Canada, [2012] 1 S.C.R. 689, 2012 SCC 20
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 24 | 120 | |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Business | "undertaking" included constructing transit system | 66 |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | alleged separate supply: a preparatory component | 277 |
Canada v. Merchant Law Group, 2010 FCA 206
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Tax Topics - General Concepts - Agency | no evidence that law firm client assumed liability to suppliers to law firm | 189 |
Commission Scolaire des Chênes v. Canada, [2002] GSTC 11, 2001 FCA 264
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | provincial subsidy was paid only if busing services provided | 182 |
See Also
Stewardship Ontario v. The Queen, 2018 TCC 59
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | performance of a statutory duty can nonetheless by a supply | 252 |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | statutorily-mandated waste recycling charges were consideration for a taxable supply | 264 |
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | statutory object of avoiding tax cascading | 369 |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service | "service" has broad meaning | 181 |
2252493 Ontario Limited v. The Queen, 2017 TCC 20
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Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | no relief from charging HST on a real estate sale where the purchaser’s bare trustee capacity was undisclosed | 288 |
GEM Health Care Group Limited v. The Queen, 2017 TCC 13
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Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | no barter of management services for HST purposes between two affiliates employing the same key manager | 320 |
Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) | issuance of credit note is mandatory for ITC claim | 159 |
Tax Topics - General Concepts - Agency | construction supplies acquired by parent as agent for subsidiary owning the real estate | 360 |
Crooks v. The Queen, 2016 TCC 52 (Informal Procedure)
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Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(a) | accommodation co-owner was not supplied her interest directly by the builder | 422 |
Tax Topics - Excise Tax Act - Section 262 - Subsection 262(3) | accommodation co-purchaser (for financing purposes) of condo was not a recipient of supply by builder | 213 |
Tax Topics - General Concepts - Substance | the addition of an accommodation co-purchaser (for financing purposes) of condo did not reflect the parties' true intentions | 167 |
Tax Topics - General Concepts - Sham | the addition of an accommodation co-purchaser (for financing purposes) of condo might have been a sham if done for tax purposes | 125 |
Tax Topics - Statutory Interpretation - Benefits-Conferring Legislation | interpretation to favour conferral of intended benefits | 183 |
PDM Royalties Limited Partnership v. The Queen, 2013 TCC 270
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Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 2 - Intermediary | no allocation on invoices | 123 |
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | internal agreement to allocate IPO costs was ineffective/services consumed rather than re-supplied | 366 |
General Motors of Canada Limited v. The Queen, [2008] GSTC 41, 2008 TCC 117, aff'd [2009] GSTC 64, 2009 FCA 114
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 91 | |
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | recipient acquires the services | 195 |
Corporation des loisirs de Neufchâtel v. The Queen, [2008] GSTC 153, 2006 TCC 339
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Bondfield Construction Company (1983) Limited v. The Queen, 2005 TCC 78
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Royal Bank of Scotland PLC v. Customs & Excise Commissioners, [2002] BTC 5280 (Court in Session (Inner House))
Customs & Excise Commissioners v. Redrow Group plc, [1999] BTC 5062 (HL)
British Airways plc. v. Customs and Excise Commissioners, [1996] BTC 5314 (Q.B.D.)
Stobbe Construction Ltd. v. The Queen, [1996] GSTC 41 (TCC)
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 280 - Subsection 280(1) | 65 |
Customs and Excise Commissioners v. Reed Personnel Services Ltd., [1995] BTC 5217 (Q.B.D.)
Harpur Group Ltd. v. Commissioners of Customs and Excise, [1995] BVC 841
Club 63 North v. The Queen, [1995] GSTC 75 (TCC), briefly aff'd [1996] GSTC o (FCA) I
P & O (Dover) Ltd. v. Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221
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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | 100 |
Administrative Policy
28 April 2017 Interpretation 154249
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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | payor of licence fees did not acquire licence and, therefore, was not recipient of supply of licence | 145 |
GST/HST Technical Information Bulletin B-032 “Expenses Related to Pension Plans” 17 November 2015
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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | investment management services provided to a pension plan viewed as supplied to the employer, and on-supplied to the plan | 72 |
B-109 "Application of the GST/HST to the Practice of Naturopathic Doctors" 31 July 2015
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26 June 2014 Ruling 157148 [double supply to and by pension plan employer]
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | double supply to and by pension plan employer | 97 |
Interpretation Revenu Québec TVQ. 16-30/R1 "Nominee Agreements" 9 December 2011
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Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | 70 | |
Tax Topics - General Concepts - Agency | 170 |
29 July 2011 Headquarters Letter Case No. 122272r
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Sale | 149 |
31 July 2003 Ruling Case No. 41263
6 December 2002 Memorandum RITS 35845
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Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 6 | 54 | |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Residential Complex | home not available to public | 53 |
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | 54 |
11 September 2000 Ruling File Nos. 11601-3, 11650-10 and 11750-5-1
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Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(c) - Subparagraph 3(c)(ii) | real estate nominee served as "representative" of beneficial owner for development expenditures | 160 |
10 April 1995 Interpretation Case No. 11945-6 [B]
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | court costs not for supply | 26 |