Précis: The taxpayer sold real property to Mayling Holding Inc. (“Mayling”) by agreement of purchase and sale executed in 2011. The transaction closed in 2012. The taxpayer did not collect and remit HST on the $3,200,000 purchase price. CRA assessed the taxpayer for $416,881.83 (the “HST Amount”) on the basis that Mayling was the recipient of the supply and was not an HST registrant. The taxpayer argued that on the date of closing Mayling held the property for the benefit of one of two possible registrants, “Baziz YYC” or “840 Holdings”.
2252493 Ontario v. R. - TCC: Appellant liable for HST - failed to prove purchaser of real estate a registrantREAD MORE »