Cases
Club Intrawest v. Canada, 2017 FCA 151
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| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) | supplies of services re cross-border vacation home portfolio split into domestic and foreign supplies | 598 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | service in relation to a cross-border vacation home portfolio split into two (GST-taxable and non-taxable) geographic components | 413 |
Felty v. Ernst & Young LLP, 2015 BCCA 445
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| Tax Topics - General Concepts - Negligence and Fiduciary Duty | accounting firm exclusion clause was binding | 192 |
Public Television Association of Quebec v. Canada (National Revenue), 2015 FCA 170
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| Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Charitable Foundation | appellant failed to control its alleged agent (a US public television station) and was its conduit | 202 |
Canada v. Merchant Law Group, 2010 FCA 206
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | law firm did not incur disbursements as agent for its clients | 69 |
Canada v. 1524994 Ontario Limited, 2007 FCA 74
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | agreements respected for supply determination purposes | 207 |
| Tax Topics - General Concepts - Evidence | agreement intended to deceive government | 208 |
Canada v. Libra Transport (BC) Ltd., [2001] GSTC 57, Docket: 98-2151-GST-G, aff’d 2002 FCA 347
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | trucker presumed not to be an unlicensed insurer | 216 |
| Tax Topics - General Concepts - Illegality | trucker presumed not to be an unlicensed insurer | 50 |
Vanex Truck Service Ltd. v. Canada, 2001 FCA 159
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | charges to fleet operators for insurance and licences were taxable resupplies | 281 |
Colbert v. The Queen, 94 DTC 6620 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Personality | 132 | |
| Tax Topics - General Concepts - Separate Existence | 132 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property | 58 |
Wharton v. The Queen, 92 DTC 6582 (FCTD)
Alberta Gas Ethylene Co. Ltd. v. The Queen, 90 DTC 6419 (FCA)
Doyle v. MNR, 89 DTC 5483 (FCTD)
London Life Insurance Co. v. The Queen, 87 DTC 5312, [1987] 2 CTC 90 (FCTD), aff'd 90 DTC 6001 (FCA)
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E.S.G. Holdings Ltd. v. The Queen, 76 DTC 6158, [1976] CTC 295 (FCA)
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| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Income of the Corporation for the Year From an Active Business | 59 |
The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 75 | |
| Tax Topics - General Concepts - Sham | no sham if documents describe intended legal rights | 338 |
| Tax Topics - General Concepts - Tax Avoidance | no sham if documents describe intended legal rights | 338 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 137 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | 195 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 55 | |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 191 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 52 |
Simard-Beaudry Inc. v. M.N.R., 74 DTC 6552, [1974] CTC 715 (FCTD)
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|---|---|---|
| Tax Topics - General Concepts - Sham | motives should not be exaggerated | 90 |
| Tax Topics - General Concepts - Tax Avoidance | motives should not be exaggerated | 90 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | cost of option included in cost of acquired asset | 26 |
| Tax Topics - Income Tax Act - Section 245 - Old | 130 |
Denison Mines Ltd. v. MNR, 71 DTC 5375 (FCTD), aff'd 72 DTC 6444 (FCA), aff'd 74 DTC 6525 (SCC)
United Geophysical Co. of Canada v. MNR, 61 DTC 1099 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | U.S. equipment rentals not attributable to Canadian services | 135 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | 100 |
See Also
Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | consideration for temps included their remuneration | 284 |
Laval Technopole v. Agence du revenu du Québec, 2018 QCCQ 6352
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Fully exempt interest - Paragraph (a) - Subparagraph (a)(iii) | traditional common law tests of Crown agency applied in determining whether companies were agents of Canadian municipalities | 268 |
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(c) | municipally influenced companies were agents of the municipality | 80 |
Jayco, Inc. v. The Queen, 2018 TCC 34
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| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) | under the UCC goods were delivered by a U.S. manufacturer outside Canada/”symbolical” delivery can occur under a bill of lading | 565 |
| Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) - Paragraph 306.1(1)(a) | issue of multiple supplies not raised in Notice of Objection (or Notice of Appeal) | 144 |
Lewski v Commissioner of Taxation, [2017] FCAFC 145
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | obligation to pay purchase price was incurred on agreement date rather than subsequent closing | 382 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) | an alternate resolution that the taxpayer was not entitled to an income distribution if Revenue denied a trust deduction made her entitlement contingent and non-includible | 356 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) | since the taxpayer through her husband as agent had knowledge of an income distribution, her subsequent purported disclaimer was not immediate | 296 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | a trust income declaration that was subject to a tax contingency did not result in an income inclusion to the beneficiary | 145 |
Zheng v. The Queen, 2017 TCC 132 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) | rebate form was signed and completed in the name of an individual who was acting as agent | 457 |
| Tax Topics - Excise Tax Act - Section 279 | rebate application made and signed as agent | 76 |
572256 Ontario Limited v. The Queen, 2017 TCC 108 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | property acquired and maintained as agent for registrant | 151 |
Persepolis Contracting Inc. v. The Queen, 2017 TCC 89 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | no evidence of implicit acceptance of agency | 85 |
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 - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | no barter of managment services between affiliates/construction supplies acquired by parent as agent for owner-subs | 192 |
Cheema v. The Queen, 2016 TCC 251 (Informal Procedure), rev'd 2018 FCA 45
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| Tax Topics - Excise Tax Act - Section 254 - Subsection 254(2) - Paragraph 254(2)(b) | unrelated individual acquiring interest as bare trustee did not deny the rebate | 285 |
Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151
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| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) | s. 142(1)(d) only applies to a supply exclusively re real property | 594 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service | payment of condo operating expenses was a service | 201 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | single supply of covering all time share operating costs | 164 |
| Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) | GST collectible based on invoicing times | 77 |
| Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | objecting to quantum was sufficient particularity | 169 |
| Tax Topics - General Concepts - Ownership | beneficial owner did not transfer property risk | 177 |
| Tax Topics - General Concepts - Evidence | foreign law assumed the same | 93 |
SNF L.P. v. The Queen, 2016 TCC 12
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| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | ITCs where reasonable efforts to verify suppliers and registration numbers, where GST not remitted | 360 |
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 2 - Intermediary | intermediary need not carry on business and may be a nominee | 125 |
| Tax Topics - Excise Tax Act - Section 261 - Subsection 261(1) | no rebate entitlement for an error caused by the applicant’s own inattention and carelessness | 104 |
McLarty v. The Queen, 2014 DTC 1162 [at 3556], 2014 TCC 30
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| Tax Topics - General Concepts - Illegality | participations contrary to agreement were disregarded | 107 |
| Tax Topics - General Concepts - Sham | sham cannot apply to just part of transaction | 139 |
| Tax Topics - General Concepts - Tax Avoidance | sham cannot apply to just part of transaction | 139 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | revenues 10% of interest | 178 |
| Tax Topics - Income Tax Act - Section 67 | leveraged purchase of seismic data at arm's length was presumptively reasonable | 282 |
2253787 Ontario Inc. v. The Queen, 2014 TCC 121 (Informal Procedure)
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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) | grey market buyers cannot be agents | 165 |
Commissioners for HM Revenue and Customs v. Secret Hotels2 Ltd., [2014] UKSC 16
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| Tax Topics - General Concepts - Substance | characterize before attaching label | 269 |
9101-2310 Québec Inc. v. The Queen, 2013 DTC 1136 [at 711], 2012 TCC 365, rev'd 2013 FCA 241
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SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181
Velcro Canada Inc. v. The Queen, 2012 DTC 1100 [at 2966], 2012 TCC 57
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|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | 264 |
Fourney v. The Queen, 2012 DTC 1019 [at 2575], 2011 TCC 520
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|---|---|---|
| Tax Topics - General Concepts - Corporate/Separate Personality | 251 | |
| Tax Topics - General Concepts - Ownership | presumption of resulting trust where property transfer for no consideration | 251 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | bare trust arising on creditor-proofing transfer | 251 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | line codes in electronic filings were incomprehensible to taxpayer | 292 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | rebuttable presumption of resulting trust on transfer for no consideration | 251 |
SLM Direct Marketing Ltd. v. The Queen, 2007 TCC 415 (Informal Procedure)
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Y S I's Yacht Sales International Ltd v. The Queen, 2007 TCC 306
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | 114 |
Arpeg Holdings Ltd v. The Queen, 2007 DTC 131, 2006 TCC 593
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| Tax Topics - General Concepts - Non Est Factum | 78 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) | 83 |
Royal Winnipeg Ballet v. Canada (Minister of National Revenue), 2006 DTC 6323, 2006 FCA 87
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 95 |
Calce Holdings Ltd. v. The Queen, 2005 DTC 959, 2005 TCC 335
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| Tax Topics - General Concepts - Price Adjustment Clause | 55 |
Key Property Management Corporation v. The Queen, 2004 TCC 210
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service - Paragraph (c) | maintenance employees working for indeterminate group companies were not their employees | 247 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | documentary requirements mandatory | 95 |
Drug Trading Company Ltd. v. The Queen, [2001] GSTC 48 (TCC) (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 204 | |
| Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) | 204 |
Skylink Voyages Inc. v. The Queen, [1999] GSTC 119 (TCC)
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Continental Bank of Canada v. The Queen, 94 DTC 1858 (TCC), aff'd at 98 DTC 6501 (SCC) after being, rev'd 96 DTC 6355 (FCA)
C&E Commissioners v. Music and Video Exchange Ltd., [1992] BTC 5028 (Q.B.)
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| Tax Topics - General Concepts - Tax Avoidance | tax minimization acceptable | 72 |
Ingram v. MNR, 91 DTC 939 (TCC)
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| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | 142 |
T. Eaton Co. v. Minister of Revenue, [1989] 1 CTC 269 (Ont CA)
Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD)
Trident Holdings Ltd. v. Danand Investments Ltd. (1988), 64 OR (2d) 65 (Ont CA)
Customs and Excise Commissioners v. Tarmac Roadstone Holdings Ltd., [1987] BTC 5074 (C.A.)
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | 103 | |
| Tax Topics - Excise Tax Act - Section 178 | 53 |
Administrative Policy
18 October 2017 Ruling 173963r
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|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 18 | members of the profession did not require membership in the Association to provide their services | 218 |
25 February 2016 CBA Roundtable, Q. 7
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | arrangement for sharing employees not a partnership in Quebec or ROC | 234 |
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | joint responsibility of joint employers | 434 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service | dentists jointly employ staff so as to avoid GST | 296 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Taxable Supply | dentists jointly employ staff so as to avoid GST | 203 |
14 October 2016 Interpretation 170549
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 273 - Subsection 273(1) | Westcan test for JV, co-tenancy was JV | 176 |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) | nominee accepted as registrant | 156 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | agent could not claim ITCs | 157 |
GST/HST Notice 284 "Bare Trusts, Nominee Corporations and Joint Ventures" February 2014
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| Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1.1) | agent not entitled to ITCs | 113 |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) | taxable supply of nominee services | 63 |
| Tax Topics - Excise Tax Act - Section 273 - Subsection 273(1) | administrative tolerance for nominee operators | 197 |
S5-F2-C1 - Foreign Tax Credit
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3 January 2014 External T.I. 2013-0507541E5 F - Crowdfunding
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15 May 2012 Ruling Case No. 142436
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service - Paragraph (c) | employees with one source-deduction account with parent treated as jointly-employed for GST purposes | 244 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | employees with one source-deduction account with parent treated as jointly-employed for GST purposes | 181 |
Interpretation Revenu Québec TVQ. 16-30/R1 "Nominee Agreements" 9 December 2011
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | 213 | |
| Tax Topics - Excise Tax Act - Section 221 - Subsection 221(2) | 70 |
GST/HST Info Sheet GI-012, Agents, November 2005
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| Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1) | 237 |
25 February 2005 Ruling Case No. 51031
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 177 - Subsection 177(1) | 28 |
GST/HST Technical Information Bulletin B-068 "Bare Trusts" Amended 10 January 2005
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| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | 48 | |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) | bare trustee required to register if it charges fees | 56 |
P-182R "Acting as an Agent" July 2003
10 January 2001 External T.I. 2000-0056135 - REPORTING TAXABLE BENEFITS
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| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | agent may fulfill employer's source deduction obligations | 139 |
16 April 1997 Memorandum 970571
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| Tax Topics - General Concepts - Ownership | 21 |
4 April 1995 External T.I. 5-950698 -
P-0016 “Acting as an Agent” 3 April 1992
IT-216 "Corporation Holding Property as Agent for Shareholder"
Articles
Emmanuel Sala, Judith Lemieux, "The Impact of Quebec Civil Law on the Recognition of Mandator-Mandatary Relationships by Quebec and Canadian Tax Authorities", Tax Topics (Wolters Kluwer), No. 2375, 14 November 2017, p. 1
Brent Murray, "Cost-Sharing, Agency & Resupply Agreements: the When and the Why", Canadian GST/HST Monitor (Wolters Kluwer), No. 329, February 2016, p.1
John G. Bassindale, Robert G. Kreklewetz, "Undisclosed Agency Questioned", Canadian Tax Highlights", Vol. 22, No.7, July 2014, p.4
Ewens, "Risk of Challenge Based on Allegation of Agency", Corporate Structures and Groups, Vol. IV, No. 1, 1996, p. 184.
Bies, "Agency and Canadian Income Tax Law", 1982 Conference Report, p. 927.
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| Tax Topics - General Concepts - Ownership | 0 |
Commentary
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