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14 May 2018- 12:07am Smith – Tax Court of Canada finds that two individuals jointly controlling a company were acting in concert respecting the payment of dividends so as to engage s. 160 Email this Content Two individuals held their 50-50 Opco through a holding company held by a family trust, in the case of Mr Smith, and through a family trust in the case of Mr Scott. ...

16 May 2018- 12:35am Pay Audio – Federal Court considers that the denial of remission of tax overpaid due to an honest mistake was not unreasonable Email this Content An agent of a partnership (Pay Audio) incorrectly told an ARQ auditor that the place of supply for digital music services supplied by Pay Audio to Telus was in Ontario rather than Alberta, and the ARQ assessed Pay Audio accordingly for uncollected Ontario HST. ...

29 May 2018- 12:28am Metrogate – Tax Court of Canada finds that the degree of completion of a condo project should reflect land costs Email this Content The size of the transitional rebate that a developer was entitled to receive on an Ontario condo project turned on whether the cost to it of the land component could be taken into account in determining its degree of “completion” on the transitional date for the introduction of Ontario HST (July 1, 2010). ...

6 June 2018- 12:36am CIBC World Markets – Tax Court of Canada finds that an ETA s. 150(1) election denied zero-rating for services provided to a parent’s non-resident branches Email this Content Administrative services provided by CIBC World Markets Inc. ...

17 July 2018- 11:16pm Patterson Dental – Tax Court of Canada finds that a zero-rating for epinephrine did not include a drug containing epinephrine Email this Content The taxpayer did not charge GST on its sales of anesthetic solutions containing epinephrine to dentists on the basis that it was making a supply of a drug that was “epinephrine.” ...

30 July 2018- 7:26am 2078970 Ontario – Tax Court of Canada finds that CRA cannot issue a s. 152(1.4) notice of determination denying partnership losses on the basis that the partnership did not exist Email this Content CRA determined that two limited partnerships did not exist because their partners were not carrying on business in common with a view to profit, and issued notices of determination to the partnerships under s. 152(1.4) determining that losses reported by the purported partnerships were, for this reason, nil. ...

30 July 2018- 7:27am THD – Tax Court of Canada finds that damages received for the “modification” of a supply contract were deemed to be GST-inclusive irrespective of an ITC to the purchaser Email this Content A trucking company (THD) had a contract with McKesson Canada for the delivery of pharmaceutical products to various locations. ...

30 August 2018- 11:31pm De Vries – Tax Court of Canada finds that a corporate creditor’s oral agreement to postpone collection of his loan defeated a RTP encompassing that loan Email this Content The two individual shareholders (husband and wife) of a corporation (“IPG”) were assessed under s. 160 regarding a dividend they had received from IPG on the basis that, at the time of the dividend, IPG had been assessed for failure to comply with a s. 224(1) requirement to pay (“RTP”) effectively requiring it to pay to CRA a demand loan owing by it to a former employee and business associate (“Houweling”). ...

18 October 2018- 12:29am National Money Mart – Ontario Court of Appeal finds that a supplier can issue an invoice after being assessed for the HST on the supply Email this Content A supplier failed to charge HST on sales of unrefined gold. ...

13 December 2018- 12:05am Apex City – Tax Court of Canada finds that a due diligence defence was not available where the taxpayer incorrectly disagreed with a CRA position Email this Content A partnership (Apex) hired a general contractor to construct condos which it then sold. ...