The Quebec Taxation Review Committee and consumption taxes June 01, 2015 Maurice Arsenault Maurice Arsenault of BĂ©langer Chabot, reports on a report by the Quebec Taxation Review Committee, which was was mandated to study Quebec taxation and propose reform measures to make it more competitive, effective and fair.
The magic GST/HST registration (or, How to make a multi-million assessment disappear) June 01, 2015 Allan J. Gelkopf and Zvi Halpern-Shavim Allan Gelkopf and Zvi Halpern-Shavim of Blake, Cassels & Graydon comment on Re 0741508 BC Ltd. and 0768723 BC Ltd. (2014 BCSC 1791), in which a nearly $6.2-million tax bill was made to disappear.
R&D costs paid to U.S. parent company by Canadian subsidiary are dutiable May 16, 2015 Jean-Guillaume Shooner and Alan Kenigsberg In a March decision, the Federal Court of Appeal upheld an International Trade Tribunal ruling that says research and development costs must be included in the price paid for footwear imported into Canada for customs valuation purposes.
Supplier’s wrongdoing irrelevant to recipient’s ITC claim May 16, 2015 John G. Bassindale and Robert G. Kreklewetz The recipient of a supply can’t be blamed for the failure of the supplier to remit the GST it collects on the sale to the government, write John Bassindale and Robert Kreklewetz of Millar Kreklewetz LLP, in their examination of a recent Quebec ruling.
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.