Section 267.1

Subsection 267.1(2)

GMCL (a car manufacturer) was the administrator of various defined benefit pension plan trusts for its employees. Royal Trust was the trustee. ...

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Locations of other summaries		Wordcount
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 - Section 104 - Subsection 104(1)	administrator of pension trust was not a trustee	41

After noting that:

s. 267.1(2) generally creates personal liability of a trustee (including the executor of an estate) for the GST/HST...

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Locations of other summaries		Wordcount
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	473

bcIMC was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act created a...

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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	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 - 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