Articles 2022

The ongoing debate about international tax avoidance (often referred to as base erosion and profit shifting, or “BEPS”) and international response such as the OECD’s BEPS Action Plan (July 2013) have focused on mainly income tax. BEPS is providing both the impetus and potentially a key missing ingredient to tackle the persistent challenge of collecting sales tax on e-commerce.

The article provides a review of the ingredients required for a partnership to exist; with a focus on the “carried on in common” requirement.

The taxpayer in Academy of Applied Pharmaceutical Sciences v. R. relied on representations of an auditor regarding a method for properly allocating between GST/HST exempt and non-exempt services. At issue, therefore, was the application of the doctrines of estoppel and officially induced error.

The article: (i) provides an overview of Canada Revenue Agency’s voluntary disclosure program; and (ii) highlights certain recent changes regarding the administration of the program.

The article provides an overview of new legislation that requires all international electronic funds transfers of $10,000 or more to be reported to the Canada Revenue Agency.