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British Columbia Investment Management Corp. v. Canada (A. G.), 2018 BCCA 47, aff'd 2019 SCC 63

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Citations
2018 BCCA 47

Case History

aff'd 2019 SCC 63

Case tabs

Summaries

Summary Under

Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125

imposition of GST on investment assets held by a provincial Crown agent would have been prohibited by its governmental immunity but for the reciprocal taxation agreement

The petitioner (“bcIMC”) was created as a provincial Crown corporation by special Act (the “PSPPA”) to manage and hold investments for...

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Summary Under

Tax Topics - Excise Tax Act - Section 122

deeming services provided by B.C. Crown agent in managing assets held in trust trenched on B.C. crown immunity

bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...

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Summary Under

Tax Topics - Excise Tax Act - Section 267.1 - Subsection 267.1(5) - Paragraph 267.1(5)(a)

services of trustees of managing assets held in trust would not be supply in absence of s. 267.1(5)(a)

bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...

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Summary Under

Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1)

arrangement under which the beneficiaries only had rights to units and no ownership of underlying assets was treated as a trust

bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...

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Summary Under

Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 19

enforcement of a reciprocal taxation agreement was possible pursuant to the Federal Courts Act

bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...

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