The taxpayer operated a business of “asset reunification”:... It did not charge GST/HST in respect of its services to the share issuer or the shareholders. The taxpayer’s position was that the services it rendered to the shareholders were tax exempt and it did not charge anything for services rendered to the share issuers. Moreover it claimed that the admissions contained in the Crown’s pleadings were sufficient to entitle it to judgement under section 170.1 of the Tax Court of Canada Rules (General Procedure). The Crown took the position that there was too much ambiguity about the application of the financial services rules to this type of structure to entitle the taxpayer to summary judgment. The Tax Court agreed with the Crown’s position and dismissed the taxpayer’s motion, with costs.
Georgeson Shareholder Communication Canada Inc. v. R. – TCC: Too much uncertainty about the application of financial services provisions to allow judgment for the taxpayer under section 170.1 of the TCC Rules in GST/HST appealREAD MORE »