Subsection 267.1(2)
Cases
Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114
GMCL (a car manufacturer) was the administrator of various defined benefit pension plan trusts for its employees. Royal Trust was the trustee. ...
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | services for pension plans represented compensation costs relating to taxable sales | 133 |
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | 99 | |
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | administrator of pension trust was not a trustee | 41 |
Administrative Policy
28 February 2019 CBA Roundtable, Q.32
After noting that:
- s. 267.1(2) generally creates personal liability of a trustee (including the executor of an estate) for the GST/HST...
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 270 - Subsection 270(4) | obtaining a clearance certificate does not relieve an executor of personal liability for estate GST/HST obligations | 459 |
Subsection 267.1(5)
Paragraph 267.1(5)(a)
Cases
British Columbia Investment Management Corp. v. Canada (A. G.), 2018 BCCA 47, aff'd 2019 SCC 63
bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...
Locations of other summaries | Wordcount | |
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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 | 515 |
Tax Topics - Excise Tax Act - Section 122 | deeming services provided by B.C. Crown agent in managing assets held in trust trenched on B.C. crown immunity | 249 |
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 | 170 |
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 | 246 |