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The King, 2022 TCC 163 (Informal Procedure)-- summary under Subsection 223(2) Summary Under Tax Topics- Excise Tax Act- Section 223- Subsection 223(2) purpose of s. 223(2) 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 TCC 163 (Informal Procedure)-- summary under Subsection 169(4) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(4) unnecessary that the GST registration number be set out in a document issued by the supplier 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 the Input Tax Credit Information (GST/HST) Regulations of “supporting documentation.” ...

. … The Minister has not considered the objection as she should have done. … ...

…In Jabel Image Concepts Inc v Canada, [2000] GSTC 45, the Federal Court of Appeal wrote at paragraph 12: When an Act uses different words in relation to the same subject such a choice by Parliament must be considered intentional and indicative of a change in meaning or a different meaning.... ...

The King, 2023 TCC 135-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions scope of a deeming provision is limited to what is clearly expressed in the provision In finding that, in the presence of a provision (s. 104(19))- which deemed the taxpayer to have received a dividend some time in its taxation year which straddled the taxation year end of the trust that made the s. 104(19) designation (to deem a dividend received by it to have been received by the taxpayer, its beneficiary) but which did not specify the particular time within the taxpayer’s taxation year in which this deemed receipt occurred- that such dividend should be considered to have been received by the taxpayer at the time at which it actually was received by the trust, D’Arcy J stated (at para. 55): Once it is determined that a deeming provision applies, one must then look at the actual wording of the deeming provision to determine what legal fiction is created. ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...

CRA considered that the substantial completion date was January 13, 2020, being the date that the local town conducted its final inspection of the property. ...

If renovations which are expressly provided for under the Act must be so substantial as to require virtually gutting all of a pre-existing premises to qualify for a rebate, additions, for which there are no express provisions in the Act, should (if they are to be considered at all) presumably be more substantial yet. ...