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8 August 2014 GST/HST Interpretation 157867 - Commission revenue earned by automobile dealers

The Dealer shall be responsible for and shall pay all taxes, including without limitation, sales and excise taxes, which may be owing in connection with the assignment of the Contracts and in connection with all amounts, including fees paid by Lender2 to the Dealer in connection with Agreement2. ... The Dealer shall be responsible for and shall pay all taxes, including without limitation, sales and excise taxes, which may be owing in connection with the assignment of the Contracts and in connection with all amounts, including fees paid by Lender3 to the Dealer in connection with Agreement3. ... INTERPRETATION REQUESTED You would like to know if commission revenues earned by the Dealers with respect to the assignment of Conditional Sales Contracts and to services provided to Lenders in connection with loans supplied by the Lenders are consideration for the supply of exempt financial services. ...

Del Zotto v. Canada, 97 DTC 5145, [1997] 2 CTC 103 (FCTD)

As to whether the plaintiffs can bring a challenge to section 231.4 and the Inquiry based purely on the right not to speak to the police, independently of any connection with the dicta of Iacobucci J. in S. ...

Vine Estate v. The Queen, 2014 DTC 1088 [at at 3130], 2014 TCC 64

Walsh suggested that the below-market rents could be attributed to poor management of Wilson and linked this to the family connection between Leadway and Biddington, the property management company owned by the deceased’s son-in-law. ...

454538 Ontario Ltd. v. MNR, 93 DTC 427, [1993] 1 CTC 2746 (TCC)

The connection that counsel is attempting to establish between the shareholder disputes which took place at various times from 1975 to 1980 is too tenuous and nebulous to be reasonably described as a link between those events and the disposition of the Tri-M shares. ...

Anthony v. The Queen, 2010 DTC 1356 [at at 4392], 2010 TCC 533 (Informal Procedure), aff'd 2012 DTC 5019 [at 6633], 2011 FCA 336

The paragraph was held to take into income a material acquisition which conferred an economic benefit, so long as the acquisition did not fall within one of the exceptions, and so long as the acquisition was received in connection with employment. 17 In Phillips v. ...

Laflamme v. The Queen, 2008 DTC 482, 2008 TCC 255

[10] The parties to this litigation saw fit to file a Partial Agreed Statement of Facts, which summarizes all the transactions that took place at this stage of the events (that is to say, starting on December 18, 1996) in connection with the transfer of the IRSL shares, and involving the Trust, the newly created 332 Canada, and the management companies held by the Appellant, his son Jean Laflamme and André Lamothe ...

Blais v. The Queen, 2011 DTC 1008 [at at 55], 2010 TCC 195 (Informal Procedure)

There were no detailed explanations about the use of the money. [69] [68] No contract was filed in evidence in connection with this loan and with the obligations between Mr. ...

Rouleau c. La Reine, 2007 DTC 1619, 2007 TCC 338 (Informal Procedure)

Cusson laid out 100% of the cost of the investment in December 1989, but then went to collect a cheque in connection with a buyback for 50% of that cost a few weeks later in January 1990 ...

Simpsons-Sears Ltd. v. Provincial Secretary (N.B.) et al., 78 DTC 6242, [1978] 2 SCR 869, [1978] CTC 296

In this connection I would quote some passages from the unanimous judgment of the Court rendered by Martland, J in Cairns Construction Ltd v Government of Saskatchewan, [1960] S.C.R. 619, holding that a builder was liable for sales tax on the price of components incorporated in houses built for a landowner or for resale (at pages 626, 627, 629 and 630): The appellant seeks to distinguish the Conlon decision and that of the Privy Council in Attorney-General for British Columbia v Kingcome Navigation Company Limited, [1934] AC 45, on the grounds that the taxes in question in those cases related to goods purchased for the purpose of consumption by the buyer, tobacco in the Conlon case, fuel oil in the Kingcome case. ...

Canada v. McLarty, 2008 DTC 6354, 2008 SCC 26, [2008] 2 SCR 79

Of necessity, where the acquisition is made by an agent of the purchaser, the purchaser’s connection to the acquisition transaction and to the question of whether the vendor and purchaser were dealing at arm’s length will require that the agreement between the agent and the purchaser be considered. ...

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