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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? 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GST/HST — no "substantial renovation" of apartment building My client was a small family-owned company. It had bought a 21-unit apartment building in Ontario that was in disrepair. It had then renovated all the units, dividing the apartments into more bedrooms so as to be able to rent them to students at a nearby university (but without changing the size of each apartment). The CRA saw that the building had gone from 26 to 47 bedrooms and decided that this meant it had been "substantially renovated". The CRA wanted to have its appraiser inspect the building and determine its value, to apply the "self-supply" rule and impose HST. The potential tax cost to my client would have been about $400,000. In one afternoon, I reviewed the facts with my client and wrote a strong letter to the auditor, showing that the definition of "substantial renovation" in the Excise Tax Act was not met. The increase in the number of bedrooms was irrelevant; there simply had not been removal or replacement of anywhere near 90% of the "insides" of the building (ignoring certain structural elements that have to be ignored under the legislation, like the outside walls, floors and roof). The auditor had told me over the phone that she was quite sure this was a substantial renovation. However, on receiving my letter, she called me back an hour later and told me she agreed with it. There was no substantial renovation and there would be no HST assessment. The CRA closed its file. Problem vanished! (2014)