Cases
Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269
In the course of finding that the appellant was receiving a financial supply from the casinos it contracted with, Sharlow JA stated (at para....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | commercial efficacy of arrangement involving kiosk and support services turned on the advance of money | 428 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | three elements integrally connected | 240 |
| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | "consideration" under law of contract | 123 |
Boardwalk Equities Inc. v. Canada, 2013 FCA 140, aff'g Calgary Board of Education v. The Queen, 2012 TCC 7
The appellant ("Boardwalk Equities") was entitled to receive amounts under an Alberta energy assistance program to defray additional costs to...
Commission Scolaire des Chênes v. Canada, [2002] GSTC 11, 2001 FCA 264
The appellant school boards paid GST charges of independent bus companies for their busing services, and were compensated with a Quebec government...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | 121 |
See Also
Laval University v. The Queen, 2016 CCI 17
Quebec City and the University of Laval entered into an agreement providing that the City would pay a grant of $10 million to the University for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 136 - Subsection 136(1) | s. 136 applied to agreement to offer, at a distant date, to license sports complex to unidentified individuals | 175 |
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - 25 | agreement to licence complex in future was not exempted becasue complex primarily used in commercial activity | 136 |
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - 2 | agreement to licence sports complex in futre to City inhabitants was a real property supply | 149 |
Invesco Canada Ltd. v. The Queen, 2014 TCC 375
The appellant, which was the manager (and also trustee) for various mutual fund trusts, charged reduced management fees to the trusts to reflect...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | discounted management fees charged by manager to MFTs not grossed up by MFT distributions of the discounts to large unitholders | 326 |
| Tax Topics - General Concepts - Evidence | evidence of surrounding circumstances including income tax objective relevant to contract interpretation | 170 |
Thompson Trailbreakers Snowmobile Club Inc. v. The Queen, [2005] GSTC 124, 2005 TCC 269
The appellant operated a snowmobile club as a member of Snowmobilers of Manitoba Inc., which was dedicated to developing and maintaining...
Commission Scolaire des Découvreurs c. La Reine, 2003 TCC 295
The City of Quebec City paid a subsidy to a school board of $880,000 to enable the school board to renovate a school and expand its gymnasium. In...
Meadow Lake Swimming Pool Committee Inc. v. The Queen, [1999] GSTC 96, Docket: 98-2588-GST-I (TCC)
Residents of a town, Meadow Lake, Saskatchewan, formed the appellant to raise funds and build a pool on town property. The town provided an annual...
Administrative Policy
18 September 2015 Ruling 168521r
As also described in 144133, Ontario Tire Stewardship (“OTS”) was designated by Waste Diversion Ontario (“WDO”) as an industry funding...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 154 - Subsection 154(2) | on-charges made to an Ontario tire seller’s customers for waste diversion fees imposed on it by Ontario Tire Stewardship are subject to HST | 189 |
22 May 2014 Ruling 156633
The Lessee of the “Property” constructed a multi-storey, multi-unit residential apartment building (the “Complex”) on the rooftop of an...
28 October 2013 Ruling 144133
Pursuant to the Waste Diversion Act, 2002 (Ontario) (“WDA”), Waste Diversion Ontario (“WDO”), a non-share corporation, is responsible for...
23 December 2002 Technical Interpretation RITS 38588
"Where a separate amount is paid by a lessee on account of property taxes, this amount is part of the consideration for the rental of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | tenant property taxes part of consideration | 66 |
| Tax Topics - Excise Tax Act - Section 165 - Subsection 165(1) | 66 |
Technical Information Bulletin B-067, "Goods and Services Tax Treatment of Grants and Subsidies," 24 August 1992
There is a direct link between a transfer payment and a supply if the payment is directly related to the provision of a supply to the grantor, or...