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Elfe Juvenile Products – Quebec Superior Court finds that the rigid GST/QST policy of not cancelling interest below 4% on wash transactions is unlawful

12 December 2017- 11:14pm Elfe Juvenile Products – Quebec Superior Court finds that the rigid GST/QST policy of not cancelling interest below 4% on wash transactions is unlawful Email this Content The CRA published policy is that it “will consider” cancelling the interest in excess of 4% for a failure to collect and remit GST/HST in a “wash transaction,” i.e., one where the purchaser is entitled to full input tax credits. ... In annulling a decision of the ARQ to only cancel interest down to the 4% level in a wash transaction (that was not covered under a voluntary disclosure), and in sending the decision back for reconsideration by the ARQ, he stated: [T]he Agency felt unable to cancel more than the interest portion indicated in … the Interpretation Bulletin of 4% of the uncollected sales tax. ... This decision is … unreasonable. Neal Armstrong. Summary of 1092072 Ontario Inc. ...

Huntly Investments – Tax Court of Canada finds that associated-corp equivalent services can be added to the actual full time employees under the SIB definition

5 January 2018- 12:31am Huntly Investments – Tax Court of Canada finds that associated-corp equivalent services can be added to the actual full time employees under the SIB definition Email this Content Paris J clarified that the over-five full time employee exclusion from a specified investment business involves a two-step test: [I]t is first necessary to know how many full-time employees the [corporation] in fact employed in the years in issue. The next step is to determine how many full-time employees would be required in respect of the services performed by … associated corporations [had those services not been provided]. ... The Queen, 2017 TCC 255 under s. 125(7) – specified investment business. ...

Bitton Trust – Quebec Court of Appeal finds that the ARQ did not exceed its Quebec-based audit authority when it issued a s. 231.2 demand to a Calgary bank branch

9 January 2018- 2:06am Bitton Trust – Quebec Court of Appeal finds that the ARQ did not exceed its Quebec-based audit authority when it issued a s. 231.2 demand to a Calgary bank branch Email this Content The ARQ, which was seeking to establish that the central management and control of an Alberta trust was in Quebec, issued a requirement to a Calgary branch of the Banque Nationale du Canada (“BNC”) for various bank records respecting the trust under the Quebec equivalent of ITA s. 231.2(1). ... In finding that the ARQ had not exceeded its territorial competence in making this requirement, Hogue JCA stated: Here we are not concerned with … a seizure outside of Quebec which, it is true, could require the seizing party to approach an authority of the foreign State with a view to obtaining its collaboration in order to proceed. … The communication of the requirement to BNC through one of its branches situated outside Quebec is the sole external element that is present here. ...

Jayco – Tax Court of Canada finds that, under the UCC, goods were delivered by a U.S. manufacturer outside Canada

4 March 2018- 7:28pm Jayco – Tax Court of Canada finds that, under the UCC, goods were delivered by a U.S. manufacturer outside Canada Email this Content A U.S. manufacturer of recreational vehicles (Jayco) was found by D’Auray J to have delivered or made available the RVs to its Canadian dealers at its facility in Indiana, so that their supply occurred outside Canada and was not subject to GST/HST. Notwithstanding a statement in the Dealership Sale Service Agreements that neither party was “the agent … of the other for any reason,” she found that, in fact, Jayco arranged for the carrier (a Jayco subsidiary) to ship the RVs to Canada on behalf of the dealers rather than of it. Given that the relevant Uniform Commercial Code provisions were broadly similar to those of the Sale of Goods Act, she quoted as apropos an Ontario judicial statement that: [I]f certain conditions are present, there may be a symbolical delivery which divests the seller’s possession …. ...

Hébert – Tax Court of Canada finds that a corporation whose only activity was unsuccessful efforts to sell its remaining equipment was carrying on an active business

3 April 2018- 11:36pm Hébert – Tax Court of Canada finds that a corporation whose only activity was unsuccessful efforts to sell its remaining equipment was carrying on an active business Email this Content The market for the business of the taxpayer’s corporation (“Radio Progressive “) of selling and repairing radio telecommunication equipment had virtually disappeared by 2007, so that from that time on, it did not make any sales, and essentially its only activity related to the efforts of the taxpayer (Mr. ... The Queen, 2018 CCI 48 under s. 248(1) – small business corporation. ...

Pelletier – Court of Quebec finds that employer payment of the law society dues of a tribunal member was not a taxable benefit

4 April 2018- 11:39pm Pelletier – Court of Quebec finds that employer payment of the law society dues of a tribunal member was not a taxable benefit Email this Content Lapierre JCQ found that the payment of the Quebec Bar dues of a commissioner of the Quebec Employment Injury Board by his employer did not give rise to a taxable benefit. ... He could have instead, as in the case of judges, ceased to pay the dues, which brought him nothing to the extent that he did not act as a lawyer. … This is especially true given that Mr. Pelletier’s function was not subject to the authority of the Barreau du Québec … nor to the Code of Professional Conduct of Lawyers. ...

DaSilva – Tax Court of Canada accepts the taxpayer’s testimony that she did not receive a notice of assessment over a CRA affidavit to the contrary

25 April 2018- 12:13am DaSilva – Tax Court of Canada accepts the taxpayer’s testimony that she did not receive a notice of assessment over a CRA affidavit to the contrary Email this Content Where a taxpayer alleges that she did not receive a notice of assessment, ETA s. 335(6) provides that an affidavit of a CRA official in charge of the appropriate records and stating that “an examination of the records shows that a notice of assessment was mailed … to a person … is evidence of [such] statement….” ...

Raposo – Tax Court of Canada finds that a partnership with an illegal business was void

9 May 2018- 12:03am Raposo – Tax Court of Canada finds that a partnership with an illegal business was void Email this Content The taxpayer and the three other members of the “Raposo clan” were involved in the sale of cocaine in the Gatineau area. ... No partnership – no s. 272.1(5) liability. Thus, the taxpayer benefited from the illegality of his venture. ... The Queen, 2018 CCI 81 under ETA s. 272.1(5) and General Concepts – Illegality. ...

Dusablon – Court of Quebec finds that a couple who renovated a house without moving in were ineligible for the principal residence exemption

14 June 2018- 12:02am Dusablon – Court of Quebec finds that a couple who renovated a house without moving in were ineligible for the principal residence exemption Email this Content Two individuals acquired a house in Montreal in a dilapidated condition for $695,000, spent $350,000 on having substantial renovations made, and put the property up for sale seven months after its acquisition at a price of $1,250,000, which was achieved in a sale two months later. ... Agence du revenu du Québec, 2018 QCCQ 3032 under s. 54 – principal residence – (a). ...

Davis – Tax Court of Canada finds that an individual who was well advanced in his steps to return to Canada had a “habitual abode” in the U.S.

20 June 2018- 11:51pm Davis – Tax Court of Canada finds that an individual who was well advanced in his steps to return to Canada had a “habitual abode” in the U.S. ... Davis … habitually lived in the U.S. Neal Armstrong. Summary of Davis v. The Queen, 2018 TCC 110 under Treaties – Income Tax Conventions- Art. 4. ...

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