Recipient

Table of Contents

Cases

Calgary (City) v. Canada, [2012] 1 S.C.R. 689, 2012 SCC 20

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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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Words and Phrases
consideration
Locations of other summaries Wordcount
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
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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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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))

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Customs & Excise Commissioners v. Redrow Group plc, [1999] BTC 5062 (HL)

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British Airways plc. v. Customs and Excise Commissioners, [1996] BTC 5314 (Q.B.D.)

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Stobbe Construction Ltd. v. The Queen, [1996] GSTC 41 (TCC)

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Locations of other summaries Wordcount
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.)

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Harpur Group Ltd. v. Commissioners of Customs and Excise, [1995] BVC 841

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Club 63 North v. The Queen, [1995] GSTC 75 (TCC), briefly aff'd [1996] GSTC o (FCA) I

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P & O (Dover) Ltd. v. Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) 100

Administrative Policy

28 April 2017 Interpretation 154249

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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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

26 June 2014 Ruling 157148 [double supply to and by pension plan employer]

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Locations of other summaries Wordcount
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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29 July 2011 Headquarters Letter Case No. 122272r

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31 July 2003 Ruling Case No. 41263

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6 December 2002 Memorandum RITS 35845

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11 September 2000 Ruling File Nos. 11601-3, 11650-10 and 11750-5-1

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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply court costs not for supply 26

GST Memorandum 700-5-10 "GST Treatment of Insurance Claims"

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GST M 300-1 "Liability for Tax" under "Liability to Pay"

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Articles

Brent F. Murray, "Inter-Company Supplies and Expense Reimbursements", Canadian GST Monitor, No. 242, November 2008, p. 1.