Cases
3533158 Canada Inc. v. Canada (the Attorney General), 2024 FC 1090
After learning from CRA that its US parent, which was its agent pursuant to s. 177, had been claiming input tax credits (ITCs) which should have...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 296 - Subsection 296(4) - Paragraph 296(4)(b) | CRA was precluded on assessing in allowing ITCs beyond the 4-year limitation period | 543 |
| Tax Topics - Excise Tax Act - Section 238 - Subsection 238(1) | global return covering 4 years was invalid | 103 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 32 | failure of return covering 4 years to allocate to component reporting periods was fundamental and not cured by s. 32 | 103 |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.1 - Subsection 18.1(2) | taxpayer did not demonstrate that CRA delays in processing its ITC claims represented undue delay | 475 |
See Also
Fazal v. The Queen, 2020 TCC 137 (Informal Procedure)
An individual carried on a proprietorship, which was registered for GST/HST purposes, and shortly thereafter incorporated that proprietorship,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 148 - Subsection 148(1) | taxpayer was eligible for the s. 166 exclusion for her current proprietorship because her GST registration was in respect of a previous proprietorship | 518 |
Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure)
Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” – whose definition includes a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 171 - Subsection 171(3) | continued to be registrant following revocation of registration number | 314 |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) | winding-down operations qualified a de-registrant as a “registrant”/registration retroactive | 212 |
| Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a) | holding discontinued equipment | 151 |
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 15
If an FI is not required to register for GST/HST purposes and chooses not to register voluntarily, it would not be a GST/HST registrant by virtue...
6 July 2012 Headquarters Letter Case No. 142921
A taxpayer which absent a s. 150 election would not have been a small supplier and had made such election on a valid basis with two financial...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 150 - Subsection 150(1) | 86 |