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He took the unusual step of ordering CRA to pay the interest, rather than remitting the matter back to CRA for further consideration. ...

17 June 2019- 8:41am CRA accepts Applewood (re GST/HST exemption for car dealers who promote, sell and process credit insurance provided to their customers) Email this Content The car dealer in Applewood entered into a “Dealer Agreement” with a distributor of credit insurance products under which it was agreed that it would “up sell” the insurance products and assist the car customers in explaining the coverage and in applying for the insurance in consideration for a commission of over 50% of the insurance premium. ...

Pizzitelli J rejected submissions that “all circumstances, including personal family circumstances and personal estate planning goals must be considered” and that the income and loss allocation methodology could be supported from the standpoint of estate planning objectives – and instead thought that “the reasonable business person would only consider factors relevant to their own business considerations having regard to their own business interest,” which confirmed his view that the focus should be on the respective capital invested and work performed. ...

The numerous “purchasers,” in consideration for a lump sum, each acquired the right, after making a reservation, to use a residence of the particular quality level (1 to 5) for which they had paid, for up to 21 days a year during the term of approximately 50 years (plus for a further 14 nights on payment of a modest charge). ...

Accordingly, he found that there was a transfer of property for insufficient consideration to which s. 160 applied at the time of the set-off transaction. ...

Dewar J also commented obiter on the subsequent enactment of s. 256(5.11), stating: I make no comment about whether that amendment if applicable in 2007- 2011 would have changed the result which I have come to on this appeal, except to say that it would have merited further consideration. ...

28 August 2019- 12:28am CRA treats bitcoin mining as a barter exchange of services for bitcoin Email this Content After finding that “Bitcoin received by a miner to validate transactions is consideration for services rendered by the miner,” and that “As cryptocurrencies are not legal tender, it follows that when a cryptocurrency is used to pay for, or is received as payment for, goods or services, this is treated as a barter transaction,” CRA stated: [W]here a taxpayer who is in the business of Bitcoin mining receives Bitcoin as a result of their mining activities, they must bring into income the value of the services rendered or the value of the Bitcoin received, whichever is more readily valued. ...

., it was consideration for the disposition of the leasehold interest (used as a principal residence) that the tenant had acquired in 2013 and held since then. ...

After referring to the Quebec equivalent of s. 67, and in finding that the taxpayer had not met its burden of establishing that such assessments were incorrect, Allen JCQ stated: How can the plaintiff challenge the presumption of correctness of the notices of assessment where the 7.89% rate, considered to be reasonable and adopted by the defendant, falls within the range that its own expert considered to be a reasonable rate based on the current rates in the market for obligations with similar considerations and risks during the period in litigation? ...

1 November 2019- 12:40am CRA finds that a GST/HST-registered non-resident marketer using services of a Canadian subcontractor was thereby making supplies in Canada Email this Content A registered non-resident (NR) does not itself have any presence in Canada but uses a resident (sub)contractor (RC) to provide marketing and soliciting services (in the credit card processing line of business) to a resident Canadian company in consideration for commissions. ...