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,…
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”…
Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of the law that courts should reject. Courts sometimes side with these taxpayers, and choose not to follow the CRA’s administrative…
In Alexander College Corp. v. Canada, 2016 FCA 269, the Federal Court of Appeal recently overturned the Tax Court of Canada on the issue of whether a private college offering an associate degree program must charge GST on its…