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Articles2023-12-19T17:45:04-05:00

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Canada Revenue Agency (CRA) Requires Written Indication to Claim Input Tax Credits (ITCs) on Rebates from Manufacturers, Distributors

March 1st, 2023|CRA, Input tax credits|

Many distributors and manufacturers provide their customers or third-party purchasers rebates on their products or services. When a GST/HST registrant pays a rebate with respect [...]

Proposed Amendments to GST/HST Rules for Cryptocurrency Mining: What’s Covered and What’s Not

January 12th, 2023|Cryptocurrency, GST, HST|

Introduction – Proposed Amendments to GST/HST Rules for Cryptocurrency Mining In February 2022, Canada’s Department of Finance released draft GST/HST legislation covering cryptocurrency mining. The [...]

Canadian GST/HST Tax Trap: ITC Record-Keeping Requirements for Canadian Businesses – Canadian Tax Guidance from a Canadian Tax Lawyer

September 16th, 2022|corporate taxation, GST, Taxation|

Introduction – The Canada Revenue Agency Targets Canadian Businesses that Keep Poor Records The Canada Revenue Agency isn’t shy about pursuing a tax audit. But [...]

Canada Proposes New GST/HST Rules for Cryptocurrency Mining– Canadian Tax Guidance from a Canadian Tax Lawyer

August 24th, 2022|Cryptocurrency, Excise Tax, GST, HST, Input tax credits|

Introduction – Draft Legislative Proposals Concerning GST/HST Treatment of Cryptocurrency Mining Since 2019, Canada has steadily introduced new GST/HST rules aimed at cryptocurrency. In May [...]

Soulliere v The Queen: Director’s Liability for Unpaid Taxes

August 1st, 2022|Case, corporate taxation, GST, HST|

What is Director’s Tax Liability? The Tax Court of Canada has recently decided a case regarding director’s liability for unremitted GST/HST returns. Generally, a director [...]

Director Hit with Vicarious Tax Liability Because She Couldn’t Prove that a Written Resignation was Sent to the Corporation: Cliff v The Queen, 2022 FCA 16 – A Canadian Tax Lawyer’s Analysis

July 29th, 2022|Case, corporate taxation, GST, HST|

Introduction: Vicarious Tax Liability for Directors & Proof of Resignation Under certain conditions, a director may become personally liable for a corporation’s unremitted net GST/HST [...]

Financial Service as an exempt supply from GST/HST – Guidance from a Canadian Tax Lawyer to Applewood Holdings Inc. v The Queen

February 25th, 2022|GST, Hello|

The GST/HST is a tax that applies to most supplies (sales) of goods and services made in Canada. The term supply means the provision of [...]

A Canadian Tax Lawyer’s Guidance on GST/HST on Shareholder Benefits

December 28th, 2021|Benefits, corporate taxation|

What is a Shareholder Benefit?  Shareholder benefits describe anything of value received by a shareholder from a corporation by virtue of the shareholder’s relationship with [...]

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