Précis: This is a somewhat unusual case in which the taxpayer seems to have been hoist with its own petard. Despite extensive and clever arguments to circumvent the section 150 election the Court held that the taxpayer was bound by it and dismissed the appeal with costs.
CIBC World Markets v. R. – TCC: Section 150 election under the Excise Tax Act precludes claiming ITCs on exported servicesREAD MORE »