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Tax law 2026 TCC 69

Heydary Green Professional Corporation v. The King

The Tax Court dismissed a GST/HST bad-debt appeal, finding no sufficient proof of individual collection efforts, no proven write-off in the books, and unmet remittance conditions.

  • Bad debt deduction
  • Write‑off requirement
  • Remittance condition
  • Books of account
  • Collection efforts
  • Gst-hst
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Excise tax act 2026 TCC 65

3278735 Nova Scotia Limited v. The King

The Tax Court allowed a GST/HST appeal in part, holding the returns were misrepresented through neglect or carelessness, but the Minister did not prove gross negligence penalties.

  • Late assessment
  • Statutory limitation
  • Penalties
  • Gross negligence
  • Reassessment
  • Section 285
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Excise tax act 2026 TCC 59

Moseley v. The King

The Tax Court held the First Floor sale was taxable, but the failure-to-file penalty was vacated after accepting the effect of retroactive GST registration cancellation.

  • Residential complex exemption
  • Subsection 9(2) exemption
  • Registration cancellation retroactivity
  • Assessments and penalties
  • Input tax credits
  • Ministerial assessment authority
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Tax law 2026 TCC 54

Darville v. The King

Appeal under section 323 of the Excise Tax Act partly allowed. The Court reduced the derivative assessment by $5,693.79 and referred the matter back for reassessment.

  • Director liability
  • Input tax credits (itcs)
  • Validity of assessments and service
  • Carousel/false invoicing allegations
  • Execution of writs of execution
  • Excise-tax-act
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Tax law 2026 TCC 50

Singh v. The King

The Tax Court dismissed an appeal from denial of the New Residential Rental Property Rebate, finding the first lease was only six months and no one-year expectation existed.

  • New residential rental property rebate
  • Qualifying residential unit
  • First use
  • Statutory interpretation
  • Reasonable expectation
  • Rebate eligibility
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Excise tax act 2026 TCC 46

Nagendra v. The King

The Tax Court dismissed a late GST/HST New Residential Rental Property Rebate appeal, holding subsection 296(2.1) did not apply and no time extension was available.

  • New residential rental property rebate (nrrpr)
  • Limitation periods
  • Statutory interpretation of s.296(2.1) eta
  • Assessment provisions
  • Estoppel
  • Discretion to extend time limits
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Tax law 2026 TCC 28

Talukdar v. The King

The Tax Court allowed Mr. Talukdar’s GST/HST new housing rebate appeal, finding he intended the condo as his primary residence and was the first occupant.

  • New housing rebate
  • Primary place of residence
  • Subsection 254(2)
  • Burden of proof
  • Credibility and evidentiary assessment
  • Gst-hst-rebate
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Tax 2026 TCC 27

Caddell v. The King

Two GST/HST appeals were denied. The Tax Court found the appellants were builders, made a self-supply of their home, could not use the personal-use exception, and owed tax based on a $915,000 value.

  • Self-supply
  • Builder
  • Subsection 191(5) exception
  • Fair market value
  • Gst-hst
  • Fair-market-value
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Excise tax act 2026 TCC 4

Maragos v. The King

The Tax Court held that the appellant ceased to be a de jure director when the corporation was dissolved and was never a de facto director, so the ETA limitation period had expired.

  • Director's liability
  • Revival of dissolved corporation
  • De jure director
  • De facto director
  • Limitation periods
  • Statutory interpretation
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Tax law 2025 TCC 186

Gaitanis v. The King

The Tax Court dismissed Lazaros Gaitanis’s appeal from a GST/HST new housing rebate assessment because he did not prove the required intention at signing.

  • New housing rebate
  • Qualification requirements
  • Intention test
  • Definition of relation
  • Frustration of contract
  • Subsection 254(2)
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.