Supply

Table of Contents

Cases

Great-West Life Assurance Company v. Canada, 2016 FCA 316

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) predominant character of insurance claim processing was administrative 234
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f.1) “financial services” definition should be applied based only on the “predominant elements” supplied 232

Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration "consideration" under law of contract 111
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service commercial efficacy of arrangement involving kiosk and support services turned on the advance of money 418
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) "consideration" under law of contract 111

Calgary (City) v. Canada, [2012] 1 S.C.R. 689, 2012 SCC 20

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Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - 24 120
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Business "undertaking" included constructing transit system 66
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient mere provision of earmarked funding did not render the Province a recipient 256

Canada v. 1524994 Ontario Limited, 2007 FCA 74

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency 252
Tax Topics - General Concepts - Evidence agreement intended to deceive government 208

Hidden Valley Golf Resort Assn. v. Canada, [2002] GSTC 42 (FCA)

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Vanex Truck Service Ltd. v. Canada, 2001 FCA 159

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency taxable resupply (made as principal) of otherwise exempt insurance 108

See Also

Stock ‘94 Szolgáltató Zrt. v Regional Customs and Finance Directorate-General for Southern Transdanubia of the National Tax and Customs Office, Hungary, Case C-208/15, [2016] BVC 45 (European Court of Justice (5th Chamber))

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f) interest on a loan funding a taxable supply of goods was part of the consideration for a single supply of the goods 268

Club Intrawest v. The Queen, 2016 TCC 149

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent 371
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) s. 142(1)(d) only applies to a supply exclusively re real property 594
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service payment of condo operating expenses was a service 201
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) GST collectible based on invoicing times 77
Tax Topics - Excise Tax Act - Subsection 306.1(1) objecting to quantum was sufficient particularity 169
Tax Topics - General Concepts - Ownership beneficial owner did not transfer property risk 177
Tax Topics - General Concepts - Evidence foreign law assumed the same 93

HMRC v National Exhibition Centre Ltd., [2016] BVC 19, Case C-130/15 (ECJ (8th Chamber))

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (a) additional “booking” charges by a service provider to those paying by credit card viewed as essentially only for exchanging information with merchant acquirer bank 537

Tele-Mobile Company v. The Queen, 2015 TCC 197

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Tax Topics - Excise Tax Act - Paragraph 142.1(2)(b) cellphone connection to a US telephone network, and transmission of call to Canada, were part of a seamless single supply to Canadian customer 278

Commissioner of Taxation v MBI Properties Pty Ltd, [2014] HCA 49

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Tax Topics - Excise Tax Act - Section 133 honouring of an executory contract entails a second supply 331

British Columbia Ferry Services Inc v. The Queen, 2014 TCC 305

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Compagnie de Gestion Alger Inc. v. The Queen, 2014 TCC 53

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Caithkin Inc. v. The Queen, 2014 TCC 80, aff'd 2015 FCA 118

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part IV - 2 resupply of foster-care services 233
Tax Topics - Excise Tax Act - Section 280 - Subsection 280(1) claiming ITCs and exempt supplies at same time 68

Casa Blanca Homes Ltd. v. The Queen, 2013 TCC 338 (Informal Procedure)

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Words and Phrases
money

Jema International Travel Clinic Inc. v. The Queen, 2011 TCC 462

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Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service taxable supply of frequent flyer points 140
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(1) - Coupon frequent flyer points could be coupons 110
Tax Topics - Excise Tax Act - Section 181.2 frequent flyer points not gift certificates 119
Tax Topics - Excise Tax Act - Section 278 - Subsection 278(1) s. 278(2) precluded direct collection on assessment of recipient until supplier released from remittance obligation 257
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) - Paragraph 296(1)(b) no double taxation in s. 296(1)(b) assessment of purchaser because supplier had been released from its remittance obligation under CCAA plan 252

Canada v. Libra Transport (BC) Ltd., [2001] GSTC 57, Docket: 98-2151-GST-G, aff’d 2002 FCA 347

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency trucker presumed not to be an unlicensed insurer 167
Tax Topics - General Concepts - Illegality trucker presumed not to be an unlicensed insurer 50

Skylink Voyages Inc. v. The Queen, [1999] GSTC 119 (TCC)

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Beynon and Partners v. Customs and Excise Commissioners, [2005] 1 WLR 86, [2004] UKHL 53

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Canada Trustco Mortgage Co. v. The Queen, 2004 TCC 792

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service sale of mortgages on fully-serviced basis 293
Tax Topics - Excise Tax Act - Section 138 sale of mortgages on fully-serviced basis with deferred purchase price labelling 239

Municipality of Lorraineville v. The Queen, [2004] GSTC 36, 2003 TCC 895 (Informal Procedure)

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Blanche's Home Care Inc. v. The Queen, [2004] GSTC 30, 2004 TCC 192 (Informal Procedure)

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Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 165 - Subsection 165(1) 151

Card Protection Plan Ltd. v. Customs & Excise Commissioners, [2001] BTC 5083 (HL)

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Parker Hale Ltd. v. Customs and Excise Commissioners, [2000] BTC 5153 (QBD)

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Winnipeg Livestock Sales Ltd. v. The Queen, [1998] GSTC 87 (TCC) (Informal Procedure)

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Imperial Drywall Contracting Inc. v. The Queen, [1997] GSTC 81 (TCC)

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Virgin Atlantic Airways Ltd. v. Customs and Excise Commissioners, [1995] B.T.C 5077 (Q.B.D.)

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O.A. Brown Ltd. v. The Queen, [1995] GSTC 40 (TCC)

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Philips Exports Ltd. v. Customs and Excise Commissioners, [1990] BTC 5082 (Q.B.D.)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 79

Customs and Excise Commissioners v. Tarmac Roadstone Holdings Ltd., [1987] BTC 5074 (C.A.)

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Customs & Excise Commissioners v. Automobile Association, [1974] 1 WLR 1447 (HL)

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Administrative Policy

21 December 2016 Ruling 157873

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) fee charged on assigning a receivable was part of the exempt consideration for the sale 197

GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017

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29 January 2016 Ruling 163020

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Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - 1 - Health Care Facility - Paragraph (a) part of facility used for multi-disciplinary preparation of health assessment reports was not for medical care 241

7 December 2016 Ruling 158637

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Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) no GST/HST on a fee charged for the cancellation of an exempt supply agreement 156
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part V.1 - 1 educational services not excluded 23
Tax Topics - Excise Tax Act - Section 232 - Subsection 232(1) choice between supplier refund or recipient rebate 100

17 December 2015 Interpretation 153009

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - 1 potential zero-rating re share issuances and dividends 86
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f) dividend a financial supply to recipient 81
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) share issuance a financial supply to shareholder 164

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 30.

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Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) settlement of right to receive full widget shipment not a taxable supply 106

26 June 2014 Ruling 157148 [double supply to and by pension plan employer]

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient double supply to and by pension plan employer 97

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 35. ("Property and Services Offer in a Senior Citizen Residence")

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part I - 6 123

28 November 2012 Ruling 116823

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15 May 2012 Ruling Case No. 142436

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service - Paragraph (c) employees with one source-deduction account with parent treated as jointly-employed for GST purposes 244
Tax Topics - General Concepts - Agency parent bearing payroll and source deductions for itself and subs 46

22 September 2011 Ruling Case No. 129475

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - 9 151

18 February 1994 TI 11,668-1

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4 April 2011 Headquarters Letter Case No. 92799

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31 March 2009 Ruling RITS 103912

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part I - 6 42

10 April 1995 Interpretation Case No. 11945-6 [B]

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient defendant became recipient of suing lawyer's supply by agreeing to pay the fee 67

Policy Statement P-218R "Tax Status of Damage Payments not Within Section 182 of the Excise Tax Act", August 10, 2007.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) 0

19 December 2003 Headquarters Letter Case No. 45870

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2 December 2003 Memorandum Case No. 41678

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24 October 2003 Ruling RITS 48006

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part I - 6 36

28 July 2003 Technical Interpretation Case No. 46063

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Memorandum 300-6-9 "Time of Liability - Consignment Sales"

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6 December 2002 Memorandum RITS 35845

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17 October 2002 Headquarter Letter 37298

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8 February 2002 Headquarters Letter 37008

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17 July 1995 Headquarter Letter File 11635-3

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Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) 75

B-067 "Goods and Services Tax Treatment of Grants and Subsidies," 24 August 1992

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P-126 "Intra-Company Cost Allocations by Foreign-Based Insurance Companies" P-077R2 "Single and Multiple Supplies" 26 April 2004

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P-061 "Extension of Transferred Payment Policy" B-067 "Goods and Services Tax Treatment of Grants and Subsidies"

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GST M 300-7-7 "Co-Operative Advertising"

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Articles

Terry G. Barnett, "The 'Dirt' on Residential Real Estate", September 2011 CICA Commodity Tax Symposium Papers

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B.S. (Simon) Thang, "EU VAT Cases and GST", Canadian Tax Focus, Vol. 3, No. 2, May 2013, p.7.

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Brent F. Murray, "Characterizing a Supply", Canadian GST Monitor, No. 267, December 2010, p.1.

W. Jack Millar, Brent F. Murray, "Potential Input Tax Credit Claim or Trap for the Unwary?", Sales and Use Tax, Vol. VI, No. 3, 2002 p. 326.

P.Z., W. Jack Millar, "GST and Mixed Supplies of Services and Intangibles", Sales and Use Tax, Vol. IV, No. 2, 1998, p. 199.