We continue to follow the U.S.-Canada trade dispute, in the context of the changing global trade situation, and will continue to update the following as required. This post updates the situation up to and including the U.S....more
4/7/2025
/ Canada ,
Countervailing Duties ,
Donald Trump ,
Executive Orders ,
Imports ,
International Trade ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
We continue to follow the U.S.-Canada trade dispute and will update this post as required.
The most recent series of events began with the White House’s March 2, 2025 announcement that, effective 12:01 a.m. EST on...more
3/13/2025
/ Aluminum Sales ,
Canada ,
CUSMA ,
Duties ,
Electricity ,
Energy Sector ,
Executive Orders ,
International Trade ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
Effective as of 12:01 a.m. EST, Tuesday, March 4, 2025, the United States imposes 25 per cent tariffs on almost all goods imported from Canada. A lower tariff of 10 per cent is imposed on Canadian energy and resource products...more
3/6/2025
/ Canada ,
Energy Sector ,
Executive Orders ,
Imports ,
International Trade ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more
Effective as of Tuesday, February 4, 2025, the United States is imposing 25 per cent tariffs on almost all goods imported from Canada. A lower tariff of 10 per cent will be imposed on Canadian energy and resource products...more
2/3/2025
/ Canada ,
Energy Sector ,
Executive Orders ,
Exports ,
Imports ,
National Security ,
Oil & Gas ,
Tariffs ,
Trade Relations ,
U.S. Commerce Department ,
US Trade Policies
New GST/HST Notice 339, published on October 25, 2024, provides that as of the first day of the fiscal year that begins on or after January 1, 2025, dentists will no longer be able to claim GST/HST input tax credits (“ITCs”)...more
Dans une décision rendue le 6 septembre 2024, la Cour du Québec (la « Cour »), sous la plume de l’honorable Daniel Bourgeois, a statué que la déduction pour créance irrécouvrable dans le calcul de la taxe nette et prévue à...more
On April 16, 2024 (“Budget Day”), the federal government released its annual budget (“Budget 2024”), which includes certain sales and excise tax measures and also confirms the government’s intention to proceed with several...more
In the Sucro Can Sourcing LLC (“Sucro Can”) decision issued on January 5, 2024 (Appeal EA-2022-002), the Canadian International Trade Tribunal (“CITT”) allowed Sucro Can’s appeal of the enforcement action taken by the Canada...more
On November 21, 2023, the Government of Canada released its Fall Economic Statement (“2023 FES”) which includes certain sales and excise tax measures, including draft legislative proposals to implement long-awaited new...more
This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more
On September 14, 2023, the Department of Finance Canada issued a news release (the “News Release”) regarding proposed legislation to be enacted in order to enhance the existing GST New Residential Rental Property (“NRRP”)...more
Bill S-211 – the Fighting Against Forced Labour and Child Labour in Supply Chains Act – which requires businesses to report on their efforts to combat forced and child labour, is set to take effect in 2024. In this post,...more
9/7/2023
/ Canada ,
Child Labor ,
Corporate Social Responsibility ,
Critical Infrastructure Sectors ,
Forced Labor ,
Human Rights ,
International Labor Laws ,
Labor Reform ,
New Legislation ,
Risk Management ,
Slavery
In July 2023, the Canada Revenue Agency (“CRA”) released GST/HST Notice 325 (the “Notice”) with respect to services provided by certain insurance intermediaries. The Notice essentially makes official the 180-degree turn the...more
9/7/2023
/ Canada ,
Canada Revenue Agency (CRA) ,
Future Tax Treatment ,
Goods or Services ,
GST ,
Insurance Agents ,
Intermediaries ,
International Tax Issues ,
Sales Commissions ,
Tax Liability ,
TPAs
On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more
On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more
7/26/2023
/ ATMs ,
Canada ,
Casinos ,
Financial Services Industry ,
Financial Transactions ,
Goods or Services ,
GST ,
International Tax Issues ,
Suppliers ,
Tax Court ,
Tax Liability
On May 11, 2023, the Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C. 2023, c. 9 (the “New Act”) received Royal Assent and became law. Formerly known as Bill S-211, the New Act requires certain...more
On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more
In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...more
On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more
The Canada Border Services Agency’s (“CBSA”) official position is that only the “importer”, the “owner” of the goods, or a licensed customs broker acting on their behalf are authorized to account for commercial goods and be...more
On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more
6/30/2022
/ Appeals ,
Automotive Industry ,
Canada ,
Canada Revenue Agency (CRA) ,
Commercial Leases ,
GST ,
Input Tax Credits ,
International Tax Issues ,
Securitization ,
Supporting Documentation ,
Tax Court ,
Tax Credits ,
Tax Planning ,
Tax Reform
On April 7, 2022, the Government of Canada unveiled its 2022 federal budget (“Budget 2022”) and announced certain important commodity tax measures. Budget 2022 includes proposed amendments to past proposals, as well as some...more
4/12/2022
/ Beer ,
Canada ,
Cannabis Products ,
Excise Tax ,
Federal Budget ,
Goods or Services ,
GST ,
Marijuana ,
Regulatory Agenda ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Vaping ,
Wine & Alcohol
On December 6, 2021, the Federal Court of Appeal (“FCA”) affirmed the Federal Court’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue), which had dismissed the taxpayers’ application for judicial...more