The Tax Court of Canada last week released a landmark decision on the GST/HST status of certain commonplace transaction processing services, namely VISA’s payment platform offering to financial institutions.
In Canadian Imperial Bank of Commerce v Her Majesty the Queen,…
A few months ago, BC announced a new “speculation tax” that will apply to certain residential properties in the province. The tax is intended to capture foreign and domestic speculators, “satellite families” who live in BC but pay little BC…
The BC government has proposed to introduce a new residential realty tax, taking effect this year. While BC has provided a general overview of the new tax by way of information sheets and public announcements, the government has yet to…
The Province of Quebec announced today that it intends to expand its requirements for non-resident vendors to collect and remit Quebec Sales Tax (“QST”) on sales to Quebec consumers, effective as early as January 1, 2019. In this context “non-resident”…
In the 2018 Federal Budget, the Department of Finance released another chapter in its saga to overhaul how private corporations and their shareholders are taxed. Finance’s initial consultation paper of July 18, 2017 (see our summary here) was met…
BC’s Property Transfer Tax Act (“PTTA”) currently taxes only registered transfers of realty. In other words, it essentially taxes transfers of legal ownership, but not transfers of beneficial ownership. Numerous BC governments have for years considered expanding the scope of…
The meteoric rise, and subsequent tailspin, in the price of bitcoin has incited rampant investment in cryptocurrencies. Over 1,400 coins or tokens are now in “circulation”. Often lost in the resplendence and chicness of buying and selling cryptocurrencies are the…
The latest chapter in the story of the “half-loaf plan” has been penned by the Federal Court of Appeal in Gervais v. the Queen, 2018 FCA 3. The case dealt with a plan by which the taxpayer, Mr. Gervais,…
The Federal Court of Appeal recently released its decision in Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2017 FCA 243. The background for the case is as follows: ConocoPhillips had been issued a reassessment of its 2000 taxation…
The Tax Court of Canada recently decided a new case under the general anti-avoidance rule (“GAAR”) in section 245 of the Income Tax Act. In Birchcliff Energy Ltd. v. The Queen, the Court held that the GAAR applied to restrict…