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Bad News: CRA Clarifies Seg Fund ITCs
Jan 16 2025 - As we blogged on here, CRA has recently taken steps to reverse what was generally understood to have been their historical position on employer eligible ITCs in pension plan situations involving insurance segregated fund products. In a recent Excis...
https://www.taxandtradelaw.com/Tax-Trade-Blog/bad-news-cra-clarifies-seg-fund-itcs.html -
Customs Assessments Must be Dealt With
Jan 08 2025 - Since 1997, the Customs Act has imposed both mandatory payment and correction obligations on importers subject to Assessments. In fact, if an importer wishes to challenge the Assessment, the only option is to first pay the assessed amount, and ...
https://www.taxandtradelaw.com/Tax-Trade-Blog/customs-assessments-must-be-dealt-with.html -
Staffing Agencies on the Hook for CPP & EI
Jan 06 2025 - Staffing agencies (as well as Employment Agencies, Temporary Labour, Placement Agencies and other similar entities – “Agencies”) play a growing role in connecting businesses with Canadian workers, but these models can come with unexpected tax “string...
https://www.taxandtradelaw.com/Tax-Trade-Blog/staffing-agencies-on-the-hook-for-cpp-ei.html -
Objections & Appeals of CRA Assessments
Dec 27 2024 - After COVID, the CRA seems to be really ramping up its audit activities, both for GST/HST and income tax matters. Once a Notice of Assessment is issued, reversing the CRA’s position becomes an uphill battle as the Objection and Appeal processes...
https://www.taxandtradelaw.com/Tax-Trade-Blog/objections-appeals-of-cra-assessments.html -
CRA Auditing Condo Assignment Sales
Dec 19 2024 - As we have written here and here, CRA is ALL over the Canadian real estate industry, assessing homebuyers, condo renters and everyone in between for GST/HST and income taxes related to use or sale of houses or condos on the suspicion of business or t...
https://www.taxandtradelaw.com/Tax-Trade-Blog/cra-auditing-condo-assignment-sales.html -
Important GST/HST Update for Dentists
Nov 25 2024 - After more than 30 years, the Canada Revenue Agency (“CRA”) is revoking an administrative arrangement with the Canadian Dental Association that simplified claiming input tax credits (“ITCs”) for GST/HST registered dental practitioners who make both t...
https://www.taxandtradelaw.com/Tax-Trade-Blog/important-gst-hst-update-for-dentists.html -
Major GST/HST "Tax Break" Announced
Nov 21 2024 - The federal government has announced that there will be a tax break from December 14th, 2024 to February 15th, 2025 on a broad range of consumer products, which is estimated will provide $1.6 billion in federal tax relief. In addition to reli...
https://www.taxandtradelaw.com/Tax-Trade-Blog/major-gst-hst-tax-break-announced.html -
SIMA Expiry Review Order: Cold-Rolled Steel
Oct 09 2024 - On September 19, 2024, the Canadian International Trade Tribunal (the “CITT”) announced an Order in Expiry Review RR-2023-006 (the “Order”), continuing its finding of material injury in respect of the dumping and subsidizing of Cold-Rolled Steel orig...
https://www.taxandtradelaw.com/Tax-Trade-Blog/sima-expiry-review-order-cold-rolled-steel.html -
Paid Too Much GST/HST? Court of Appeal Confirms the only Redress is through the Excise Tax Act
Oct 08 2024 - In yet another interesting legal battle involving Uber, the Ontario Court of Appeal has confirmed that even when a party overpaid on GST/HST, there is no right to recover that tax from the person or company that charged that tax. This means the only...
https://www.taxandtradelaw.com/Tax-Trade-Blog/paid-too-much-gst-hst-court-of-appeal-confirms-the-only-redress-is-through-the-excise-tax-act.html -
New GST/HST E-Filing Returns: More Detailed Information Now Required!
Sep 19 2024 - As we have previously written about here, the CRA has been modernizing its electronic services. As part of these changes, the CRA has updated the GST/HST e-filing returns to require additional lines of detail. Businesses e-filing their GS...
https://www.taxandtradelaw.com/Tax-Trade-Blog/new-gst-hst-e-filing-returns-more-detailed-information-now-required.html -
Reverse and Rebills: A GST/HST Minefield
Sep 18 2024 - "Reverse and rebill" situations are very common in the Oil, Gas and Petrochem industry, especially in situations where goods are delivered in one reporting period but invoiced (or reversed and rebilled) in another reporting period because of formul...
https://www.taxandtradelaw.com/Tax-Trade-Blog/reverse-and-rebills-a-gst-hst-minefield.html -
Fuel Charge Reporting: Counter-Intuitive Unexpectedly Complicated?
Sep 17 2024 - With the new Canadian fuel charge provided for in the Greenhouse Gas Pollution Pricing Act (the “GGPPA”), many Canadian and non-resident oil and gas companies doing business in Canada with fossil fuel products have now successfully registered. ...
https://www.taxandtradelaw.com/Tax-Trade-Blog/fuel-charge-reporting-counter-intuitive-unexpectedly-complicated.html -
House Flipping & Dual Motivations: GST for Home Builders and Renovators
Sep 16 2024 - As we have blogged about here and here, the CRA is after a whole swath of residential homeowners who are finding themselves being taxed on the sale of their new or used residential properties, after substantially renovating them. A recent decision o...
https://www.taxandtradelaw.com/Tax-Trade-Blog/house-flipping-dual-motivations-gst-for-home-builders-and-renovators.html -
Director's Personal Liability Assessments: 'Due Diligence' Requires Timely CRA Payments
Sep 06 2024 - As we have blogged here and here, dealing with and appealing Director’s Liability Assessments for GST/HST purposes or source withholding purposes on the Income Tax side is generally an uphill battle. The Tax Court’s recent decision in Donalds...
https://www.taxandtradelaw.com/Tax-Trade-Blog/director-s-personal-liability-assessments-due-diligence-requires-timely-cra-payments.html -
New Surtax on Chinese EV Trade: Canada Announces a 100% Surtax on Chinese-Built EVs
Sep 05 2024 - On August 26, 2024, the Canadian government announced a series of new measures to support Canadian workers in an effort to enhance the country’s electrical vehicle (“EV”) industry in domestic, North American, and global markets. This fo...
https://www.taxandtradelaw.com/Tax-Trade-Blog/new-surtax-on-chinese-ev-trade-canada-announces-a-100-surtax-on-chinese-built-evs.html -
GST/HST 101: Division II & III Supplies
Sep 04 2024 - Since the GST was first implemented in 1991, a continual source of misconception has been that the GST represents a single tax. In fact, there are potentially four different applications of the GST – i.e., reflected in Divisions II through IV...
https://www.taxandtradelaw.com/Tax-Trade-Blog/gst-hst-101-division-ii-iii-supplies.html -
GST/HST Rebate for Purpose Built Rentals
Aug 30 2024 - As we wrote in a previous blog post, the federal government amended subsections 256.2(3.1) and (3.2) of the Excise Tax Act (the “ETA”) to introduce an enhanced GST/HST residential rental property rebate applicable to new purpose-built rentals (the ...
https://www.taxandtradelaw.com/Tax-Trade-Blog/gst-hst-rebate-for-purpose-built-rentals.html -
Masks are no Longer Zero Rated: Their Tax Status is "Back to Normal"!
Aug 29 2024 - Bill C-69, which received Royal Assent on June 20, 2024, contains various amendments to implement the federal government’s 2024 Budget. In this blog, we discuss a small but important amendment: supplies of certain face masks, respirator...
https://www.taxandtradelaw.com/Tax-Trade-Blog/masks-are-no-longer-zero-rated-their-tax-status-is-back-to-normal.html -
CRA's Digital Service Transformation: Non-Residents' Access to CRA Electronic Documents
Aug 19 2024 - Over the past several years, the Canada Revenue Agency (the “CRA”) has been in the midst of a digital service transformation. Like the CBSA’s “CARM” project, which we previously discussed here, this initiative appears to be a response to the Ca...
https://www.taxandtradelaw.com/Tax-Trade-Blog/cra-s-digital-service-transformation-non-residents-access-to-cra-electronic-documents.html -
Divided Jurisdiction for Tax Disputes
Jul 24 2024 - Our tax system is complex, with many potential procedural pitfalls that taxpayers need to navigate. One such issue is the jurisdictional boundaries between the Tax Court and the Federal Court for tax disputes. Recent Supreme Court’s compa...
https://www.taxandtradelaw.com/Tax-Trade-Blog/divided-jurisdiction-for-tax-disputes.html