2021

Today
Today

Death knell for resisting RFIs?

  • March 14, 2022
  • Rob Kreklewetz & Stuart Clark

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

Commodity Tax, Customs and Trade

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.

Commodity Tax, Customs and Trade

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.

Commodity Tax, Customs and Trade

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)).

Commodity Tax, Customs and Trade

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.

Commodity Tax, Customs and Trade

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.

Commodity Tax, Customs and Trade

Eyes half open

  • May 20, 2021
  • Stuart Clark and Robert G. Kreklewetz

Wilful blindness under section 285 of the ETA.

Commodity Tax, Customs and Trade

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.

Commodity Tax, Customs and Trade

Ensuring food safety for Canadians

  • April 01, 2021
  • Heather Innes

What you need to know about the Canada Food Inspection Agency’s recent reminder.

Commodity Tax, Customs and Trade