Input Tax Credit Information (GST/HST) Regulations

Section 2

Intermediary

See Also

Agence du revenu du Québec v. Stamatopoulos, 2018 QCCA 474

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) burden shifted to ARQ once taxpayer showed that it had business dealings with suppliers named in invoices 246
Tax Topics - General Concepts - Onus onus shifted to ARQ once the taxpayer had demonstrated that he had business deaings with issuer of mooted invoice 199

SNF L.P. v. The Queen, 2016 TCC 12

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) ITCs where reasonable efforts to verify suppliers and registration numbers, where GST not remitted 360
Tax Topics - Excise Tax Act - Section 261 - Subsection 261(1) no rebate entitlement for an error caused by the applicant’s own inattention and carelessness 104
Tax Topics - General Concepts - Agency "prête‑nom" contract is a valid contract 197

PDM Royalties Limited Partnership v. The Queen, 2013 TCC 270

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient intragroup expense-bearing agreement did not change the recipient of services rendered on IPO 276
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) internal agreement to allocate IPO costs was ineffective/services consumed rather than re-supplied 366

Tchebotar v. The Queen, [2013] GSTC 43, 2013 TCC 32 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 285 sales records shredded 49

Administrative Policy

GST Memorandum (New Series) 8.4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Finance

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Supporting Documentation

Administrative Policy

23 March 2017 CBA Commodity Taxes Roundtable, Q.19

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) - Paragraph 232(3)(a) incorrect invoice could be corrected with a letter 71

Section 3

Paragraph 3(a)

See Also

Rochus Geissel, as liquidator of RGEX GmbH v Finanzamt Neuss (Neuss Tax Office), C 374/16, [2017] BVC 58 (European Court of Justice, 5th Chamber)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Subsection 13(1) a letter box address is a valid address for VAT purposes 449

Les Ventes et Façonnage de Papier Reiss Inc v. The Queen, 2016 TCC 289

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

23 March 2017 CBA Commodity Taxes Roundtable, Q.11(b)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 271 an unpaid GST/HST remittance obligation can be offset against an ITC if the vendor and purchaser amalgamate 235

Paragraph 3(b)

Subparagraph 3(b)(i)

See Also

THD Inc. v. The Queen, 2018 CCI 147

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 182 damages received for the “modification” of a supply contract were deemed to be GST-inclusive irrespective of an ITC to the purchaser 172

Paragraph 3(c)

Subparagraph 3(c)(ii)

See Also

2253787 Ontario Inc. v. The Queen, 2014 TCC 121 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency grey market buyers cannot be agents 165

Administrative Policy

23 March 2017 CBA Commodity Taxes Roundtable, Q.18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) where a partnership reimburses a partner for a partnership expense, an invoice on file in the partner’s name is satisfactory 212

11 September 2000 Ruling File Nos. 11601-3, 11650-10 and 11750-5-1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
representative
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient beneficial owner was recipient of contracts entered into in name of nominee 61

Subparagraph 3(c)(iv)

See Also

Construction S.Y.L. Tremblay Inc. v. Agence du revenu du Québec, 2018 QCCA 552

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis Court of Quebec not bound by Tax Court decisions/stare decisis does not preclude relitigation where unfairness would otherwise result 208
Tax Topics - General Concepts - Abuse of Process taxpayer’s attempt to relitigate an adverse TCC decision in the Court of Quebec was an abuse of process given that the new evidence to be tendered did not address its defective invoices 386
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) failure of invoices to describe supply was in itself sufficient to deny credit 168

Barlis 06 - Investimentos Imobiliários e Turísticos SA v. Autoridade Tributária e Aduaneira, [2016] EUECJ C-516/14 (European Court of Justice (Fourth Chamber))

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) requirement to grant credit if registrant provides non-invoice back-up 427

Construction S.Y.L. Tremblay inc. v. The Queen, 2013 TCC 406 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Bijouterie Almar Inc. v. The Queen, 2010 TCC 618, [2010] GSTC 181

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Other locations for this summary
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) Vendor had capacity to provide goods

Administrative Policy

23 March 2017 CBA Commodity Taxes Roundtable, Q.3

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.