Case study: Techtronic Industries Canada inc. c. Agence du revenu du Québec April 02, 2015 Jean-Guillaume Shooner and Nathaniel Lacasse Jean-Guillaume Shooner and Nathaniel Lacasse of Stikeman Elliott look at a July 2014 decision of the Court of Quebec that established the impact of commercial terms like “free on board” when deciding whether to apply the Quebec sales tax to…
New CBSA voluntary disclosure policy for relief of interest and penalties April 02, 2015 Dalton J. Albrecht Dalton Albrecht of Couzin Taylor LLP examines the Canada Border Services Agency’s recent Memorandum D11-6-4, which sets out new guidelines for voluntary disclosures of errors in customs declarations – or failures to report at all.
Requirement to file new and existing GST/HST closely related party elections March 30, 2015 Allan Gelkopf and Zvi Halpern-Shavim Allan Gelkopf and Zvi Halpern-Shavim of Blake, Cassels and Graydon examine recent amendments to the Excise Tax Act (Canada), which affects the date on which elections under Section 156 to be filed with the Canada Revenue Agency.
Importers may benefit from reversal of CBSA policies March 30, 2015 Jean-Guillaume Shooner and Alan Kenigsberg Jean-Guillaume Shooner and Alan Kenigsberg of Stikeman Elliott say changes to the Canada Border Services Agency’s position on the treatment of downward price adjustments in value for duty calculations could be of benefit for many importers.
Related party R&D/design costs dutiable in Canada May 01, 2014 Dalton Albrecht Dalton Albrecht of Couzin Taylor LLP examines Skechers USA Canada Inc. v The President of the Canada Border Services Agency, which he calls one of the most important customs cases in years.
Eligibility for input tax credit claims on initial public offering and placement expenses – and beyond May 01, 2014 Jamie Wilks and Carl Irvine The authors compare Tax Court rulings in A&W Trade Marks Inc. v. The Queen and PDM Royalties Limited Partnership v. The Queen, which offer conflicting jurisprudence on the question of eligibility to claim input tax credits.
2014 federal budget: important GST/HST issues May 01, 2014 Alan Kenigsberg and Jean-Guillaume Schooner The federal budget tabled in 2014 contains some items of interest for tax lawyers, including changes to the election for closely related persons under the Excise Tax Act; and the rules regarding registration for the purposes of the GST/HST.
The Canada - EU Free Trade Agreement demystified: new opportunities for trade, investment and government procurement May 01, 2014 Daniel Kiselbach and Itti Ma The Canada – European Union Comprehensive Economic and Trade Agreement will pay dividends to Canadian and EU businesses for years to come, write Daniel Kiselbach and Itti Ma of Deloitte Tax Law.
Single vs. multiple supplies, and financial services: tricky even for the experts May 01, 2014 Robert Kreklewetz and John Bassindale Characterizing a supply for GST/HST purposes is a challenge. Characterizing a supply of a bundle of financial services for GST/HST purposes is a near Herculean task, write Robert Kreklewetz and John Bassindale of Millar Kreklewetz.
Canada Revenue Agency allows temporary GST/HST relief for joint ventures May 01, 2014 Allan Gelkopf and Zvi Halpern-Shavim Allan Gelkopf and Zvi Halpern-Shavim of Blakes look at GST/HST Notice No. 284, “Bare Trusts, Nominee Corporations and Joint Ventures,” released on Feb. 6, 2014.