Canadian Bar Association

May 02, 2022
Héléna Gagné and Alan Kenigsberg

Draft select luxury items tax legislation is released, with a start date of September 1, 2022.

March 14, 2022
Rob Kreklewetz & Stuart Clark

Resisting CRA attempts to gain access to information is not a good idea.

CBSA issues verification targets for 2022

January 31, 2022
Greg Kanargelidis

A review of best practices to help importers know in advance the types of issues the CBSA will be targeting in their customs audits each year.

GST/HST Elections: Why Being Late Is Not Always Fashionable (Cont’d)

January 31, 2022
Jean-Guillaume Shooner

Analyzing the Federal Court of Appeal’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue)

The Bloom Lake decision

December 23, 2021
Jean-Guillaume Shooner and William Rodier-Dumais

Restricting the tax authorities’ use of set-off in the context of CCAA proceedings.

Assessment period waivers under ETA Section 298(7) waivers: Pitfalls and practice

December 02, 2021
Rob Kreklewetz and Stuart Clark

A common oversight by taxpayers in GST/HST matters is the execution of unconditional waivers under subsection 298(7) of the Excise Tax Act (the “ETA”) (see also the functionally equivalent Income Tax Act (“ITA”) provisions at subsections 152(4)(a)(ii), (4.01)(a)(ii), and (4.1)).

GST/HST Applies to A Bank's Payments in Connection with its Participation in a Loyalty Rewards Program: Federal Court of Appeal Upholds Tax Court Decision

July 27, 2021
Jean-Guillaume Shooner

In a decision released on May 20, 2021, the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada’s decision that the supply of Aeroplan Miles to a Canadian bank (the “Bank”) pursuant to the Aeroplan Mile loyalty program (“Aeroplan Mile Program”) was in fact part of a single supply of promotional and marketing services by Aeroplan Limited Partnership (“Aeroplan”) to the Bank and thus subject to GST/HST.

Settling tax disputes

June 18, 2021
Rebecca D. Loo and Robert G. Kreklewetz

Important factors for taxpayers to consider when engaging in settlement discussions with the Canada Revenue Agency.

Eyes half open

May 20, 2021
Stuart Clark and Robert G. Kreklewetz

Wilful blindness under section 285 of the ETA.

How long can the CRA hold your net tax refund?

April 29, 2021
Rebecca D. Loo and Robert G. Kreklewetz

What constitutes “all due dispatch” is unclear and recent court cases suggest taxpayers are at the mercy of the CRA.

Tracking Preferences

2022