832866 - Tax Court of Canada finds that failure to ask GST questions about a self-supply is neglect

Under the GST self-supply rule, if a newly-constructed home held in inventory commences to be licensed or leased for personal use, GST is triggered on its fair market value.  I am explaining this because it may not be well known.

A small company failed to recognize the application of this rule when its shareholders started to use such a house for personal use which it couldn’t sell.  Rip CJ found that this constituted neglect which opened up an otherwise statute-barred reporting period: the novelty of this situation should have "disturbed" it sufficiently to ask a chartered accountant about the GST treatment.

Neal Armstrong.  Summary of 832866 Ontario Inc. v. The Queen, 2014 TCC 93 (Informal Procedure) under ETA - s. 298(4).