What kinds of cases are you looking for?    < Previous Case Collections — holding off on collecting on incorrect GST/HST assessmentGST/HST — Advertising servicesGST — air travel commissionsGST — builder built home for personal useGST — builder of new home was not who CRA thought it wasGST/HST — Cancelling interest on "wash transaction"GST — cleaning up years of failure to charge GST on management feesGST — community centre constructionGST/HST — convincing CRA that it was too late to assessGST — corporation providing health care servicesGST/HST — credit for net tax wrongly remittedGST — dental clinicGST — 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 directorGST — employee rebate more than 10 years backGST/HST — exported goodsGST/HST — fixing a failed voluntary disclosureGST — full input tax credits allowedGST — getting CRA to honour a retroactive registrationGST — golf club membershipsGST — home renovation was not substantial renovationGST — input tax credits allowed without documentationGST/HST — input tax credits for GST incurred before registrationGST/HST — input tax credits for joint venture investmentGST/HST — input tax credits for legal fees on selling company sharesGST — input tax credits justifiedGST/HST — input tax credits on bulk purchases of iPhonesGST/HST — input tax credits on inputs to exempt suppliesGST — input tax credits on land held for developmentGST/HST — input tax credits where CRA had cancelled supplier's GST registrationGST — interest reduced to reflect offsetting rebateGST — liability of charitable institution for unremitted GSTGST/HST — litigation over real estate purchaseGST — medical devicesGST — miscellaneous adjustmentsGST/HST — new housing rebateGST/HST — net tax refund approvedGST/HST — no "substantial renovation" of apartment buildingGST — partnership assessment was out of timeGST — purchase of real estateGST/HST — purchases by President as agentGST — rebate for ship towed out of the countryGST/HST — rebate to builder of student residenceGST — recognizing when a second objection had to be filedGST/HST — recovering HST not paid on sales incentivesGST/HST — recovering tax from customers after CRA assessmentGST — reducing assessment by almost 90%GST/HST — reducing assessment on self-supply of new homeGST — registrants were not associatedGST — reopening audit after expiry of appeal periodGST — retroactively deeming a business to be GST-registeredGST — sales of condominiumsGST — school board's liability eliminatedGST — services to insolvent companies were zero-ratedGST/HST — services to US company were zero-ratedGST/HST — services were zero-ratedGST — stopping a client from being driven out of businessGST — summer camp teaching English as a second language was exemptGST — tax on purchase of commercial propertyGST — tire installer neglecting to bill GSTGST — townhouse renovationsGST/HST — valuation of student residenceGST — voluntary disclosure — negotiating interest relief and income tax offsetGST — voluntary disclosure acceptedGST — voluntary disclosure of GST collected on commercial rentsGST — voluntary disclosure of management feesGST — waiver of interestGST — waiver of interest and penaltyGST — waiver of penaltyGST — wash transactionGST — were courses educational or recreational?PST — director's liabilityPST — directors' liability (car dealership)PST — directors' liability re data conversion projectPST — eliminating assessment for tax collected by franchisorPST — invoices written up incorrectlyPST — reducing tax on sale of book with CD-ROMPST — refund of tax on supermarket constructionIncome tax — $2 million payment on retirement was tax-freeIncome tax — another refund where return filed lateIncome tax — assessment for transfer by tax debtorIncome tax — auditor demanding too muchIncome tax — builder built home as personal residenceIncome tax — cancelling source deductions assessmentIncome tax — capital gains vs. incomeIncome tax — charitable donation of kidney beansIncome tax — charitable donation to US religious schoolIncome tax — child support deductionIncome tax — claiming business losses from past yearsIncome tax — companies were not carrying on Personal Services BusinessIncome tax — corporation was bare trusteeIncome tax — costs of mother's Notice of Objection deductibleIncome tax — CRA chasing widow for deceased's RRSPIncome tax — deduction for Power of Attorney feesIncome tax — donations to suspect charity allowedIncome tax — expenses against unreported incomeIncome tax — expenses of setting up a film shelterIncome tax — general anti-avoidance ruleIncome tax — getting the $500,000 capital gains exemptionIncome tax — getting Third Level Fairness reviewIncome tax — income from UN agency was tax-freeIncome tax — income not earned personallyIncome tax — intercompany charges deductibleIncome tax — liability of deceased's estate for UK pension incomeIncome tax — no tax on litigation settlementIncome tax — officers of company were acting as outside sales reps, not employeesIncome tax — over-intrusive auditIncome tax — professional fees deduction allowedIncome tax — refunds where returns filed lateIncome tax — "reserve" was not a reserveIncome tax — RRSP on deathIncome tax — sale of condo was not a "flip" for profitIncome tax — tax savings on selling homeIncome tax — taxpayer did not realize she was non-resident and exempt from Canadian taxIncome tax — trust for disabled childIncome tax — voluntary disclosureIncome tax — wages of family members were deductibleIncome tax — waiver of TFSA penalty taxIncome tax — withholding tax on deemed dividendIncome tax and GST — real estate agent's business expensesCollections — execution preventing sale of propertyPayroll withholdings — directors' liability (company dissolved)Payroll withholdings — directors' liability (public company)Payroll withholdings — penalty for late remittanceYour problem goes here Next Case > GST — miscellaneous adjustments My client, a small incorporated business, was audited for GST. The auditor felt he was not getting much cooperation from my client and his accountant, and issued an assessment for over $40,000, covering a wide range of GST matters. I was retained after the assessment had been issued, and when I reviewed the file in detail I found a number of errors in the auditor's work, as well as additional information and analysis which could have been provided to the auditor and had not been. I prepared a Notice of Objection that covered numerous issues, each of which was relatively small. These included: (1) Expenses incurred by the company's owners on behalf of the company. The auditor had disallowed input tax credits because the charges were not billed directly to the company. I presented documentation showing that there was an agency arrangement so that the owners were entitled to incur these expenses as the company's agent. (2) Missing input tax credits. The client had additional invoices which the auditor had not reviewed. I submitted a detailed schedule showing the allowable credits. (3) GST inclusion from an disbursements billed to customers. I requested "wash transaction" relief so that minimal penalty and interest would apply, and my client obtained payment of the GST from the customers. (4) GST inclusion on the basis that a refund had been received from a supplier for a computer that my client had purchased. I showed that the supposed "refund" had actually been a separate sale to that supplier, for which GST had been properly accounts. (5) GST inclusion for an invoice for $12,000 which had been split up into two separate invoices for internal accounting purposes, and double-counted by the auditor. The GST had only been billed to the client once and only paid out. (6) GST inclusion for an invoice for which the revenues were split with another party. The auditor considered that my client should have collected and remitted all of the GST; my client had only collected and remitted half, since that was its share of the invoice. (7) Input tax credits for charges from the company's owners for services provided to the company. Because no invoice was issued until year-end, the auditor disallowed the credits to the company for earlier periods. I showed that records on the company's computer were sufficient to constitute "supporting documentation" as required by the GST regulations. The Canada Customs & Revenue Agency Appeals Officer agreed with all of my submissions, and reduced the assessment by over $30,000. Combined with amounts of GST that I assisted my client in obtaining from its customers, virtually the entire assessment was wiped out. Problem vanished! (1999)