Section 122 - Application

Cases

Canada (Attorney General) v. British Columbia Investment Management Corp., 2019 SCC 63

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) statutory trust was not necessarily a “trust” 271
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125 ETA taxes that would be borne by portfolio of which a Crown agent was legal owner would contravene s. 125 298
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 “trust” interpreted in accordance with its common law meaning 349

British Columbia Investment Management Corp. v. Canada (A. G.), 2018 BCCA 47, aff'd 2019 SCC 63

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125 imposition of GST on investment assets held by a provincial Crown agent would have been prohibited by its governmental immunity but for the reciprocal taxation agreement 483
Tax Topics - Excise Tax Act - Section 267.1 - Subsection 267.1(5) - Paragraph 267.1(5)(a) services of trustees of managing assets held in trust would not be supply in absence of s. 267.1(5)(a) 164
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) arrangement under which the beneficiaries only had rights to units and no ownership of underlying assets was treated as a trust 164
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 19 enforcement of a reciprocal taxation agreement was possible pursuant to the Federal Courts Act 232

Reference re Goods and Services Tax, [1992] 2 S.C.R. 445, [1992] GSTC 2

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125 imposing a GST collection obligation on the Province on supplies made by it did not violate s. 125 157

See Also

British Columbia Investment Management Corp. v. Canada (A. G.), 2016 BCSC 1803

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125 BC Crown agent immune from HST otherwise imposed on investments held by it in a statutory trust, but bound to such HST based on intergovernmental agreement 472

Administrative Policy

GST/HST Memorandum 18-2 “Provincial Governments” February 2020

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31 May 2012 Quebec Information Bulletin 2012-4

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Related Provisions

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Related Provisions

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Paragraph 122(b)

Administrative Policy

GST/HST Memorandum 18-2 “Provincial Governments” February 2020

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