Section 306.1

Subsection 306.1(1)

Cases

Canada v. Telus Communications (Edmonton) Inc., 2005 FCA 159

The taxpayer was a specified person and raised in its Notice of Appeal in the Tax Court of Canada the issue of due diligence with respect to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) due diligence defence not raised 174

See Also

The Toronto-Dominion Bank v. The King, 2024 TCC 50

TD, whose appeal was focused on the question of whether payments which it made to Aeroplan for purchase Aeroplan Miles were not subject to HST on...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply the single supply test entails a predominant element, not a predominant purpose, test 246
Tax Topics - Excise Tax Act - Section 181.2 gift certificate, money 321

Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151

The Appellant charged annual time share maintenance fees to its individual members in October of each year, but charged its two members who were...

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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 377
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 632
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service payment of condo operating expenses was a service 211
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of covering all time share operating costs 172
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) GST collectible based on invoicing times 79
Tax Topics - General Concepts - Ownership beneficial owner did not transfer property risk 183
Tax Topics - General Concepts - Evidence foreign law assumed the same 101

Ford Motor Company of Canada Limited v. The Queen, 2015 TCC 39

The appellant, a "specified person" under ETA s. 301, referred in its notice of objection to requests it had made to an auditor in the course of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) Minister was presumed to understand the scope and quantum of issues that had been raised during audit 80

British Columbia Transit v. The Queen, [2006] GSTC 103, 2006 TCC 437

After having incurred substantial GST in acquiring a transit system for exempt use, the appellant commenced to lease the system to another...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(1.1) lease consideration not nominal because of property tax obligation 174
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(3) lessor required to demonstrate taxable-supply-for-consideration purpose 148
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) lease consideration not nominal because of property tax obligation 61

Paragraph 306.1(1)(a)

See Also

Jayco, Inc. v. The Queen, 2018 TCC 34

The appellant (Jayco), a U.S.-resident registrant and a specified person, was assessed on the basis that its sales of recreational vehicles to...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) under the UCC goods were delivered by a U.S. manufacturer outside Canada/”symbolical” delivery can occur under a bill of lading 595
Tax Topics - General Concepts - Agency statement in agreement that taxpayer was not an agent was not followed in practice 142

Subsection 306.1(2)

Administrative Policy

27 February 2020 Report of the Quebec Ombudsman entitled "“So that taxpayers’ rights are upheld in payment arrangement proposals with Revenu Québec”

Extract from Conclusions

The rules that Revenu Québec must follow to enter into a valid transaction at the administrative stage are numerous and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) direction to the ARQ as to the principles to be followed in reaching settlements 168