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Tax

2520356 Ontario Corp. v. The King

Appeal partly allowed on HST reassessment. The Court held the property sale was exempt because the renovation was abandoned after demolition and before substantial reconstruction.

  • Residential complex
  • Substantial renovation
  • Builder status
  • Input tax credits
  • Exempt supply
  • Assessment and reassessment
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Tax law

Becker v. The King

The Tax Court dismissed Mr. Becker’s GST/HST appeal, finding Westgate was built in an adventure or concern in the nature of trade, and that he never occupied it.

  • New housing rebate
  • Self-supply rules
  • Builder status
  • Adventure or concern in the nature of trade
  • Occupancy of a new house
  • Alternative basis or argument
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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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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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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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Tax law 2025 TCC 145

Sharma v. The King

Appeal by Mandeep Sharma under the GST/HST New Housing Rebate was allowed. The Tax Court found she intended to occupy the property as a primary residence and did occupy it.

  • New housing rebate
  • Intention to occupy
  • First occupancy
  • Section 254(2)(b) and 254(2)(g)
  • Gst-hst
  • New-housing-rebate
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Tax law 2025 TCC 132

Elhav v. The King

The Tax Court dismissed Yoram Elhav’s appeal from a GST/HST New Housing Rebate denial, finding the evidence did not prove a settled intention at purchase.

  • New housing rebate
  • Eligibility
  • Intention to occupy
  • Occupancy requirement
  • Credibility assessment
  • New-housing-rebate
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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.