(416) 864 - 6200

Tax Lawyer's Desk at Millar Kreklewetz

Computer Hardware & Software


MILLAR KREKLEWETZ LLP has significant experience and expertise in the Computer Hardware and Software and High Tech Industries, with our core practice encompassing all commodity tax, customs and trade issues facing the Computer and High Tech Industries in Canada .

Core Areas of Practice

Our core practice areas as they relate to the Computer Hardware and Software and High Tech Industries includes as follows:

Customs & Trade

GST & Sales Tax


Tariff Classification

Advice Re: the GST and PST Issues Associated with the Negotiation of Aircraft Purchase/Lease Agreements

Excise Taxes

Customs Valuation

Application of GST/ ITC Entitlement with respect to Aircraft Imported into Canada

Provincial Gasoline & Fuel Taxes

Customs Origin

Application of GST & Customs Duties to Aircraft Temporarily Imported into Canada

Provincial Sales Tax

Customs Import/Export Requirements

Application of GST / ITC Entitlement with Respect to the Acquisition of Aircraft including corporate, partnership, financial institutions and individual acquisitions

Tax & Customs Considerations in Establishing a Business in Canada

Customs Compliance for Non-Residents

Application of GST to Maintenance and Repairs Performed in Canada on Non-Residents Aircraft

Joint Venture Elections

AMPS Assessments

GST Rules Re: International & Domestic Passenger Air Travel

Transfer Pricing

Ascertained Forfeitures & Seizures

GST Drop Shipment Rules

Advice Re: Registration of Aircraft

Customs Correction Obligations

Application of GST to Passenger Charges

Related Litigation

Import / Export Verification Reviews

GST Change in Use Rules Re: Change in Use of Aircraft


Voluntary Disclosures

Application of GST to Aerospace Services


NAFTA Verifications

GST Compliance for Non-Residents


CBSA Verifications and Audits

Application of PST to Aircraft


World Trade Organization (WTO) Matters



Recent Achievements

While not exhaustive of our work in the Computer Hardware and Software and High Tech Industries, some Recent Achievements of MILLAR KREKLEWETZ LLP in this Industry are as follows:

  • Application of PST to Computer Software and Services. MILLAR KREKLEWETZ LLP has extensive knowledge and experience regarding the various provincial rules relating to the application of PST to computer software and related services. MILLAR KREKLEWETZ LLP is currently involved in an Ontario retail sales tax appeal involving the application of Ontario retail sales tax to computer replacement parts and warranty and maintenance services.
  • Lease Termination Payments. MILLAR KREKLEWETZ LLP successfully appealed an Ontario retail sales tax assessment to the Ontario Court of Appeal which held that lease termination payments made in respect of leased computer equipment were not subject to retail sales tax
  • Structuring Agreements. MILLAR KREKLEWETZ LLP has extensive knowledge and experience in advising and structuring agreements for the acquisition of high tech goods and services.
  • Customs and NAFTA Verification. MILLAR KREKLEWETZ LLP has advised a number of high tech companies that have come under audit by Canada Customs for customs and NAFTA Origin compliance


MILLAR KREKLEWETZ LLP also undertakes Tax & Trade Litigation before all relevant bodies, tribunals and courts affecting the Computer and High Tech Industries, including before the Canadian International Trade Tribunal, the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, and Canadas various provincial Superior Courts, and Courts of Appeal, and provides a full range of Planning and Representation services in all of the above areas as well..

Client Base

Our Broad Client List includes many blue chip corporate clients, who are national and international leaders in high tech industry, and we continue to work on Canadian specific issues related to the Canadian and American Computer and High Tech Industries.

Thinking about Establishing
a Computer or High Tech Business in Canada ?

MILLAR KREKLEWETZ LLP provides comprehensive full service assistance for non-resident businesses establishing operations in Canada , including the following additional specialized advice:

  • Advice and direction as to the Business Structure appropriate for Canadian operations
  • Business Incorporation and Corporate and Trade Name Registrations
  • Basic Corporate & Income Tax Planning Advice
  • Basic GST & Sales Tax Planning Advice
  • Basic Customs & Trade Planning
  • Provincial Registration & Licensing
  • Advice on Canadian Privacy Legislation including Development of a Corporate Privacy Policy

Toronto Office

10 Lower Spadina Avenue, Suite 200, Toronto, Ontario, M5V 2Z2 Canada
Phone: (416) 864-6200| Fax: (416) 864-6201

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