We are a super-boutique Canadian tax and trade law firm, with litigation and planning expertise in tax, trade, GST/HST and customs matters. Our client base is comprised of national and international leaders in almost every industry sector who have come to rely on us for the specific and cost-effective litigation services and advice that we can provide.
When matters cannot be resolved with the governmental authorities to our clients’ satisfaction, we represent them in tax and trade litigation before all relevant courts, and at all levels of court, including before the Tax Court of Canada, the Canadian International Trade Tribunal, the Federal Court and Federal Court of Appeal, and the Supreme Court of Canada.
Our tax practice includes a focus on Canada’s GST/HST system, which is a multi-level, value-added taxing system, imposed under Canada's Excise Tax Act (the ETA), and administered by the Canada Revenue Agency (the CRA). The GST applies at a 5% rate federally, and the HST applies an additional provincial component by province, resulting in GST/HST rates ranging from 5% to 15% nationally.
Our Customs and Trade practice focuses on all Canadian issues affecting the movement of goods to and from Canada, including tariff classification, origin, valuation, marking, seizures and ascertained forfeitures, and export controls. Our trade practice also includes assisting clients on NAFTA, and Anti-Dumping & Countervail (SIMA) matters, and much much more.
Our firm has a special focus on direct selling companies. Our firm is truly a “one stop shop” for direct sellers looking to expand into the Canadian marketplace. From tax structuring assistance to help with incorporation, to compliance with Canada’s anti-pyramid laws and provincial consumer protection licensing, we have assisted hundreds of direct selling companies in the Canadian marketplace with their legal compliance, including four of the last six DSA Rising Star Award winners!
BUDGET 2025 HARD TO CELEBRATE BUT PROPOSES SOME GOOD INDIRECT TAX CHANGES
Canada's Budget 2025 was launched on November 4th with the energy of a lead balloon. Despite the doom and gloom focus on the continuing deficit financing by the Liberal Government – off-loading our current woes on the backs of our children and grandchildren – there were some (largely) positive changes from an Indirect Tax perspective.
Canada’s “Luxury Tax” implemented under the Select Luxury Items TaxAct (“SLITA”) has been a significant development for vendors, importers and buyers of high-priced vehicles, aircraft and vessels. As we have previously discussed here, the SLITA imposes tax obligations that require careful compliance, including registration and record keeping.
Recently, the CRA released a new guidance document clarifying how third-party rebates impact the calculation of tax owing under the SLITA. The main message is straightforward but significant – rebates from manufacturers or other third parties do not reduce the taxable value of luxury items and do not lower the amount of tax vendors and importers must pay!
On September 1, 2022, the Select Luxury Items Tax Act(“SLITA”) officially came into effect. Vendors and importers of subject goods should be registered with the Canada Revenue Agency (“CRA”), paying tax, and keeping track of the information they will need to file their first returns.
While we have written about the luxury tax previously, this blog provides further practical details on the implementation of the luxury tax in light of the CRA’s recently-released administrative guidance.