Yesterday, the Department of Finance announced GST relief for new residential rental construction. In addition to signaling a reduction in the cost of supplying new rental homes, the measure potentially reduces or eliminates a major source of friction between…
When is an allocation of costs amongst supplies “fair and reasonable” for calculating input tax credits (“ITCs”)? In Marine Atlantic Inc. v The King (2023 TCC 95), the Tax Court confirmed that a “fair and reasonable” allocation:
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The Canada Border Services Agency (“CBSA”) released a consultation paper and proposed regulations amending the Valuation for Duty Regulations on May 27, 2023, with a thirty-day consultation period that ends June 26, 2023. A copy of the proposed regulations…
Budget 2023 – A Made-in-Canada Plan: Strong Middle Class, Affordable Economy, Healthy Future (“Budget 2023”) was tabled by the Department of Finance (“Finance”) on March 28, 2023 (“Budget Day”). The stated focus of Budget 2023 includes targeted inflation relief, stronger…
Under the Excise Tax Act (the “Act”), the Minister of National Revenue (“Minister”) and her delegates are granted discretion to make administrative decisions affecting taxpayers on a case-by-case basis, including powers to extend deadlines or waive compliance with certain requirements…
At the end of March, the BC Supreme Court released its decision in Chemainus Gardens RV Resort Ltd. v The Queen, 2020 BCSC 478. The decision is potentially of great assistance to contractors in BC who install goods that become…
On June 23, 2020, the CRA released its National Business Resumption Plan (the “NBRP”) for CRA employees. This follows the CRA’s previous announcement that it would be transitioning from a critical services mode to a business resumption mode on June…
As part of its COVID-19 Economic Response Plan, the Government has taken a number of steps to alleviate hardships faced by taxpayers. As discussed in our previous blog post, these measures include filing deadline extensions and payment deferrals to…
In these heady days of cryptocurrency investment, the market can seem like a gold rush: offering promise, but at the expense of predictability. The taxation of cryptocurrencies is no different. In this article, a collaboration between the Fintech Team…
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,…