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Application for extension of time to file notice of objection dismissed as out of time.
The applicant applied for an extension of time to file a notice of objection to GST/HST assessments.
The Minister refused the extension.
The Court found it had jurisdiction to hear the application because the Minister's decision letter was not sent by registered or certified mail as required.
However, the Court concluded that the assessment notices were properly sent to the applicant's authorized representative via electronic notification in the CRA's My Business Account.
Because the applicant failed to request an extension within one year of the deadline to object, the application was dismissed.
Appeals dismissed; condominium sale was an adventure in the nature of trade and subject to GST.
The appellant purchased a pre-construction condominium in 2015 and sold it in 2018, claiming the principal residence exemption.
The Minister reassessed her under the Income Tax Act, including the gain as business income from an adventure or concern in the nature of trade, and under the Excise Tax Act, finding she was a builder required to collect GST on the sale.
The Tax Court dismissed both appeals, finding the appellant acquired the property with a speculative intent and did not occupy it as a place of residence.
Appeal dismissed; support payments under a consent order not identifying spousal support are non-deductible child support.
The appellant appealed the reassessment of his 2019 taxation year, which denied the deduction of $33,000 claimed as spousal support.
The payments were made pursuant to a Consent Order that did not identify any portion of the $8,000 monthly support as being solely for the support of the former spouse.
The Tax Court of Canada held that under subsection 56.1(4) of the Income Tax Act, the entire amount was considered a child support amount and was therefore not deductible.
The appeal was dismissed.