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Vega International – ECJ finds that a parent’s funding of fuel costs of subsidiaries was a provision of credit rather than a purchase and on-sale of the fuel

18 July 2019- 11:52pm Vega International – ECJ finds that a parent’s funding of fuel costs of subsidiaries was a provision of credit rather than a purchase and on-sale of the fuel Email this Content The parent (Vega International) of a transport group of companies provided fuel cards to its subsidiaries (e.g., Vega Poland) which drivers used to purchase fuel, with Vega International charging Vega Poland on a monthly basis for the cost of the fuel plus a 2% surcharge. ... Summary of Vega International Car Transport and Logistic — Trading GmbH v. Dyrektor Izby Skarbowej w Warszawie, ECLI:EU:C:2019:412 (European Court of Justice, 8 th Chamber) under ETA s. 1223(1) – financial service – (g). ...

Applewood – Tax Court of Canada finds that a car dealer who promoted and processed credit insurance to its customers was supplying a GST/HST exempt “arranging for” service

Pizzitelli J applied the single supply doctrine in finding that the predominant element of what was being supplied by the dealer was an exempt supply of arranging for the insurance – and that the exclusion in (r.4) of the definition of an exempt financial services for promotional and various administrative services did not apply. ... In our case, that is the car buyer who buys the insurance product and he would clearly and objectively know he was buying insurance, not the expertise or training, or commercial efficacy or profitability of the Dealer or its staff as the predominant elements of the transaction, notwithstanding that such services … may have an ancillary role to play in his decision making process…. ... The Queen, 2018 TCC 231 under ETA s. 123(1) – financial service – (r.4). ...

LPIC – Federal Court of Appeal finds that LPIC was not exempt under s. 149(1)(d.5) because its owner, the Law Society, did not provide municipal-type services

22 May 2020- 12:02am LPIC – Federal Court of Appeal finds that LPIC was not exempt under s. 149(1)(d.5) because its owner, the Law Society, did not provide municipal-type services Email this Content Lawyers’ Professional Indemnity Co. did not qualify under s. 149(1)(d.5) as being owned by a “municipal or public body performing a function of government in Canada” because its parent, the Law Society of Upper Canada, although a “public body,” did not satisfy the test of “performing a function of government.” ... The Law Society did not so qualify because its “primary focus … is on the regulation of the legal profession in Ontario, and it does not provide the type of services that are typically provided by municipalities or municipal bodies in a localized geographical area.” ... Canada, 2020 FCA 90 under s. 149(1)(d.5) and Statutory Interpretation – Interpretation Act – s. 14, Redundancy and Consistency. ...

Ray-Mont – Federal Court of Appeal confirms applying 4-part Wiebe test to find employment notwithstanding intent of Quebec parties not to be employer-employee

10 September 2020- 11:33pm Ray-Mont – Federal Court of Appeal confirms applying 4-part Wiebe test to find employment notwithstanding intent of Quebec parties not to be employer-employee Email this Content Notwithstanding that a logistics company and workers performing loading work for it had intended their relationship to be one of independent contractors rather than of employment, the Tax Court went on to apply the four objective tests in Wiebe as to the presence of an employment relationship to find that there was one. ... This is a different articulation of the tests than by Graham J in Insurance Institute- that under “ Connor Homes … a different test must be applied [than in Wiebe] when the worker and the payor share a common intention.” ... Canada (National Revenue), 2020 FCA 113 under s. 5(1) and General Concepts – Judicial Comity. ...

Fyfe – Tax Court of Canada rejects a CRA position that a taxpayer who regularly reported business income was not carrying on a business

22 February 2022- 11:02pm Fyfe – Tax Court of Canada rejects a CRA position that a taxpayer who regularly reported business income was not carrying on a business Email this Content The taxpayer spent approximately six months per year doing work for one client (mostly construction and repair work), and the balance of the year sailing in the Bahamas. ... CRA denied his WITB claims on the surprising basis that he had no source of income and, therefore, no income – rather than on the basis that he was under-reporting his income. ... The Queen, 2022 CCI 20 under s. 122.7(1) – working income – para. (c). ...

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). ...

CRA indicates that subjecting dividend income paid to a preferred beneficiary to TOSI accords with tax policy – but that it’s easy to avoid the designation

16 June 2019- 9:38pm CRA indicates that subjecting dividend income paid to a preferred beneficiary to TOSI accords with tax policy – but that it’s easy to avoid the designation Email this Content As noted re Q.13, CRA considers that the exclusion from para. ... Summary of 7 June 2019 STEP CRA Roundtable, Q.14 under s. 120.4(1) – split income – s. ...

Wardlaw – Tax Court of Canada notes that the effective s. 163(2) penalty rate can exceed 50% where there has been a loss carryback

29 September 2019- 10:13pm Wardlaw – Tax Court of Canada notes that the effective s. 163(2) penalty rate can exceed 50% where there has been a loss carryback Email this Content The taxpayer claimed a fictitious business loss of over $357,000, and requested that the excess of the claimed loss over what he could use in the current year be carried back to the prior three years. ... The Appellant may wish to consider making an application for a reduction of the penalty and interest under … subsection 220(3.1) …. ...

Thinaddictives – Court of Quebec finds that a contribution of capital by a US shareholder was incorrectly recorded as debt, and reversed thin cap assessments

26 July 2022- 12:11am Thinaddictives – Court of Quebec finds that a contribution of capital by a US shareholder was incorrectly recorded as debt, and reversed thin cap assessments Email this Content The Canadian taxpayer (“Thinaddictives”), which was initially formed by its US parent (“Nonni”) with nominal issued share capital, received approximately $19 million from Nonni to fund the cash portion of the purchase price for an asset acquisition. $10 million of this was clearly interest-bearing debt, but the balance of around $9 million did not have any resolution or other legal documentation establishing its character. ... Agence du revenu du Québec, 2022 QCCQ 3029 under s. 18(5) – equity amount – (a)(ii). ...

Axamit Versa – Tax Court of Canada finds that the GST registration number need not be set out in a document issued to the ITC claimant by the supplier

27 December 2022- 8:57pm Axamit Versa – Tax Court of Canada finds that the GST registration number need not be set out in a document issued to the ITC claimant by the supplier Email this Content The ARQ denied input tax credits claimed by Axamit for its 2015 year regarding GST charged by its landlord, because Axamit had not provided the ARQ with any document issued by the landlord as the ARQ considered to be required by the definition in Input Tax Credit Information (GST/HST) Regulations of “supporting documentation.” ... The King, 2022 CCI 163 under Input Tax Credit Information (GST/HST) Regulations – s. 2 – supporting documentation and ETA s. 223(2). ...

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Vega International – ECJ finds that a parent’s funding of fuel costs of subsidiaries was a provision of credit rather than a purchase and on-sale of the fuel

Applewood – Tax Court of Canada finds that a car dealer who promoted and processed credit insurance to its customers was supplying a GST/HST exempt “arranging for” service

LPIC – Federal Court of Appeal finds that LPIC was not exempt under s. 149(1)(d.5) because its owner, the Law Society, did not provide municipal-type services

Ray-Mont – Federal Court of Appeal confirms applying 4-part Wiebe test to find employment notwithstanding intent of Quebec parties not to be employer-employee

Fyfe – Tax Court of Canada rejects a CRA position that a taxpayer who regularly reported business income was not carrying on a business

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

CRA indicates that subjecting dividend income paid to a preferred beneficiary to TOSI accords with tax policy – but that it’s easy to avoid the designation

Wardlaw – Tax Court of Canada notes that the effective s. 163(2) penalty rate can exceed 50% where there has been a loss carryback

Thinaddictives – Court of Quebec finds that a contribution of capital by a US shareholder was incorrectly recorded as debt, and reversed thin cap assessments

Axamit Versa – Tax Court of Canada finds that the GST registration number need not be set out in a document issued to the ITC claimant by the supplier

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