Article & Tips
Statute-Barred Years for GST/HST Returns: When the CRA Can Reassess and How to Protect Your Rights
Understanding Statute-Barred Years for GST/HST Returns Taxpayers expect a degree of finality when it comes to the Canada Revenue Agency’s (CRA) authority to reopen previously [...]
Why ‘Primary Residence Intent’ Matters to Residential Real Estate Owners, Investors: GST/HST New Housing Rebate – Lisi v. The King (2025 TCC 106)
GST/HST New Housing Rebate – Why Proving Your Intention to Reside Is Critical The GST/HST New Housing Rebate, as outlined in section 254 of the [...]
How NOT to apply for GST/HST rebate for owner-built homes: Case Commentary on Charleboix v HMK
No rebate for an owner who did not build a home as his primary place of residence In May 2025, the Tax Court of Canada [...]
The GST/HST Implications of Changing the Use of Personal Property – How Subsections 199(3), 200(2), and 200(3) Interact
Introduction: Navigating Property Use Changes Under the Excise Tax Act Registrants under the Excise Tax Act are responsible for collecting and remitting the GST/HST payable [...]
MedSleep Inc v The King – Sleep Clinic Wrongly Assessed for Failing to Pay GST/HST for Providing Services to its Doctors Because it was ‘Exempt Supply’
Introduction: MedSleep's Processes & the Minister's Assessments MedSleep Inc v The King, 2025 TCC 70 was a case before the Tax Court of Canada that [...]
Case Commentary: Osman v The King – GST/HST New Housing Rebate Claim Denied Due to Lack of Intention to Occupy Property First
Introduction: Claim to New Housing Rebate Denied Osman v The King, 2025 TCC 65 [Osman] involves the New Housing Rebate (the “Rebate”) found in section [...]
House-flippers beware: You are not eligible for GST/HST new housing rebates – Ram v HMK, 2025 TCC 49
Introduction – Self-represented litigant tried to defend a house-flip In March 2025, the Tax Court of Canada delivered the judgment on Aneeta Ram v His [...]
Builders Beware: GST/HST Now Applies on all ‘Assignment Sales’ (Pre-Construction Contracts) – Guidance from a Canadian Tax Lawyer
As of May 7, 2022, changes introduced by the Federal Budget 2022 have amended Part IX of the Excise Tax Act (ETA), significantly impacting assignment [...]
Case Study: How Rotfleisch & Samulovitch helped reduce the tax owed by ON Corp to CRA from $140,000 to $3,000
Brief Situation Overview The taxpayer operates an online store via Shopify that sells all kinds of jerseys to customers in North America, the UK, France [...]








