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Collections — holding off on collecting on incorrect GST/HST assessment GST/HST — Advertising services GST — air travel commissions GST — builder built home for personal use GST — builder of new home was not who CRA thought it was GST/HST — Cancelling interest on "wash transaction" GST — cleaning up years of failure to charge GST on management fees GST — community centre construction GST/HST — convincing CRA that it was too late to assess GST — corporation providing health care services GST/HST — credit for net tax wrongly remitted GST — dental clinic GST — directors' liability (car dealership) GST — directors' liability (company dissolved) GST — director's liability (construction contractor) GST — director's liability (corporate lawyer) GST — directors' liability (person never agreed to be a director) GST — directors' liability (public company) GST — director's liability (restaurant owner) GST — directors' liability assessment — individual was never a director GST — employee rebate more than 10 years back GST/HST — exported goods GST/HST — fixing a failed voluntary disclosure GST — full input tax credits allowed GST — getting CRA to honour a retroactive registration GST — golf club memberships GST — home renovation was not substantial renovation GST — input tax credits allowed without documentation GST/HST — input tax credits for GST incurred before registration GST/HST — input tax credits for joint venture investment GST/HST — input tax credits for legal fees on selling company shares GST — input tax credits justified GST/HST — input tax credits on bulk purchases of iPhones GST/HST — input tax credits on inputs to exempt supplies GST — input tax credits on land held for development GST/HST — input tax credits where CRA had cancelled supplier's GST registration GST — interest reduced to reflect offsetting rebate GST — liability of charitable institution for unremitted GST GST/HST — litigation over real estate purchase GST — medical devices GST — miscellaneous adjustments GST/HST — new housing rebate GST/HST — net tax refund approved GST/HST — no "substantial renovation" of apartment building GST — partnership assessment was out of time GST — purchase of real estate GST/HST — purchases by President as agent GST — rebate for ship towed out of the country GST/HST — rebate to builder of student residence GST — recognizing when a second objection had to be filed GST/HST — recovering HST not paid on sales incentives GST/HST — recovering tax from customers after CRA assessment GST — reducing assessment by almost 90% GST/HST — reducing assessment on self-supply of new home GST — registrants were not associated GST — reopening audit after expiry of appeal period GST — retroactively deeming a business to be GST-registered GST — sales of condominiums GST — school board's liability eliminated GST — services to insolvent companies were zero-rated GST/HST — services to US company were zero-rated GST/HST — services were zero-rated GST — stopping a client from being driven out of business GST — summer camp teaching English as a second language was exempt GST — tax on purchase of commercial property GST — tire installer neglecting to bill GST GST — townhouse renovations GST/HST — valuation of student residence GST — voluntary disclosure — negotiating interest relief and income tax offset GST — voluntary disclosure accepted GST — voluntary disclosure of GST collected on commercial rents GST — voluntary disclosure of management fees GST — waiver of interest GST — waiver of interest and penalty GST — waiver of penalty GST — wash transaction GST — were courses educational or recreational? PST — director's liability PST — directors' liability (car dealership) PST — directors' liability re data conversion project PST — eliminating assessment for tax collected by franchisor PST — invoices written up incorrectly PST — reducing tax on sale of book with CD-ROM PST — refund of tax on supermarket construction Income tax — $2 million payment on retirement was tax-free Income tax — another refund where return filed late Income tax — assessment for transfer by tax debtor Income tax — auditor demanding too much Income tax — builder built home as personal residence Income tax — cancelling source deductions assessment Income tax — capital gains vs. income Income tax — charitable donation of kidney beans Income tax — charitable donation to US religious school Income tax — child support deduction Income tax — claiming business losses from past years Income tax — companies were not carrying on Personal Services Business Income tax — corporation was bare trustee Income tax — costs of mother's Notice of Objection deductible Income tax — CRA chasing widow for deceased's RRSP Income tax — deduction for Power of Attorney fees Income tax — donations to suspect charity allowed Income tax — expenses against unreported income Income tax — expenses of setting up a film shelter Income tax — general anti-avoidance rule Income tax — getting the $500,000 capital gains exemption Income tax — getting Third Level Fairness review Income tax — income from UN agency was tax-free Income tax — income not earned personally Income tax — intercompany charges deductible Income tax — liability of deceased's estate for UK pension income Income tax — no tax on litigation settlement Income tax — officers of company were acting as outside sales reps, not employees Income tax — over-intrusive audit Income tax — professional fees deduction allowed Income tax — refunds where returns filed late Income tax — "reserve" was not a reserve Income tax — RRSP on death Income tax — sale of condo was not a "flip" for profit Income tax — tax savings on selling home Income tax — taxpayer did not realize she was non-resident and exempt from Canadian tax Income tax — trust for disabled child Income tax — voluntary disclosure Income tax — wages of family members were deductible Income tax — waiver of TFSA penalty tax Income tax — withholding tax on deemed dividend Income tax and GST — real estate agent's business expenses Collections — execution preventing sale of property Payroll withholdings — directors' liability (company dissolved) Payroll withholdings — directors' liability (public company) Payroll withholdings — penalty for late remittance Your problem goes here
Next Case > GST/HST — Cancelling interest on "wash transaction" My two clients were sales representatives who worked for a store that sold appliances. Several appliance manufacturers paid extra commissions or allowances to sales reps who sold their brands of appliance. These were arranged through an "incentives" agent that handled the payments, and were unrelated to the sales reps' salary and commissions from the store that employed them. My clients were both very successful and had substantial revenues from these incentives. The manufacturers issued T4As to them, and they reported these revenues for income tax purposes and paid tax on them. The CRA audited my clients for GST/HST, concluded that they had failed to collect and remit substantial amounts of HST, and assessed them. The clients and their accountant then came to me for advice about appealing the assessment. They had also asked the incentives agent about getting payment of the HST, but had been given the runaround. I advised the clients that the assessments were correct and should not be appealed, but that they could recover the HST from the manufacturers, and I helped them do that successfully. I also helped them apply for relief from the CRA under its "wash transaction" policy, to cancel most of the interest charged to them (something the auditor should have done and failed to do). Unfortunately, the request I made to the Audit section was sent to the CRA's Taxpayer Relief section, which did not understand the "wash transaction" policy and refused to cancel interest under the regular Taxpayer Relief policy. I filed a request for a Second Administrative Review, explaining in detail that Taxpayer Relief had misunderstood my earlier request and had not correctly applied CRA policy. Finally the CRA got it right, and cancelled most of the interest under the "wash transaction" administrative policy. Problem solved! (2017)