A Ltd. incurred the following legal fees with respect to

A Ltd. incurred the following legal fees with respect to its business for the current year:

 Representation to the Federal government …………………………………………………………. $8,000

 Review of purchase agreement and registration of title for a new office building ……5,000

 Letters with respect to overdue …………………………………………….. 2,000

 Registering the mortgage on the new office building …………………………………………….. 1,000

Determine the deduction permitted for tax purposes for the current year. Income tax reference: ITA 18(1), 20(1)(e), 20(1)(cc).

You are an Examiner for the Refund Integrity Program in

You are an Examiner for the Refund Integrity Program in the GST/HST Audit Division of the Canada Revenue Agency (CRA). Using sophisticated analytical tools, you are able to identify GST/HST returns that have a high risk of containing errors or omissions. You are currently working on a pre-assessment review for a GST/HST return filed by Kellogg Adelaide Ltd. (KAL) for its April 1–June 30, 20X6 reporting period.

The return was filed claiming a refund of $62,973. Using records accessible by the CRA, you are able to determine that KAL was incorporated on February 4, 20X6 and has not yet filed a corporate tax return. The company also registered a GST/HST account on April 25, 20X6 with an effective registration date of April 1. The period under review is KAL’s first GST/HST filing.

You have sent a pre-assessment review letter to the business address on file requesting a description of the commercial activity, a detailed general ledger of sales and input tax credits (ITCs), and copies of the five largest sales and purchasing invoices. KAL’s accounting controller has submitted the following information in response to your letter:

• KAL is engaged in the development and construction of a new residential condominium building at 9000 Adelaide Street in Toronto, Ontario. The parcel of land was purchased on April 25, 20X6 for $6,000,000. Revenue will come from the sales of the individual condominium units upon the building’s completion in 5 years.

• The only revenue in the period was a management fee of $25,000 received from Kellogg Yonge Street Inc. (KYSI), a corporation wholly owned by the same individual who owns KAL. No HST was charged on this fee by KAL and no ITC was claimed by KYSI since the parties have made a closely related group election. The controller was able to provide a copy of the completed election form.

• The following breakdown was provided for the $62,973 of ITCs reported:

• The five largest supplier invoices were provided. For the site management fee invoice, the “billed to” displays the name of KYSI. KAL’s controller explains that this particular vendor does work for both entities and incorrectly printed the wrong name on this invoice. The controller was able to provide proof of payment that the invoice was paid by KAL and not KYSI.


Determine what adjustments should be made to KAL’s GST/HST return and calculate the revised refund or balance owing. Be sure to explain your adjustments.

Determine whether each of the following is a taxable supply,

Determine whether each of the following is a taxable supply, zero-rated supply, or exempt supply.

(a) A clothing store sells a pair of jeans to a customer.

(b) Jessica provides consulting services to a large US private company in Delaware. The services are performed in the United States.

(c) Same situation as (b), except the services are performed at Jessica’s office in Ontario.

(d) A pharmacy sells a prescription drug to an individual.

(e) Syed purchases a newly constructed cottage in Ontario for personal use.

(f) A Canadian bank charges a monthly service fee for the use of a chequing account.

(g) Jacob sells a used piece of commercial real property situated in British Columbia to a non-resident located outside of Canada.

Fine Furnishings Canada Inc. (FFC) is a manufacturer of hand-crafted

Fine Furnishings Canada Inc. (FFC) is a manufacturer of hand-crafted wood furniture. The company has decided to discontinue its line of outdoor patio furniture and picnic tables. FFC is planning to sell off various assets relating to these product lines to Cottage Living (CLC). The sale includes the following:

(a) Remaining inventory will be shipped from FFC’s warehouse in British Columbia to CLC’s warehouse in Ontario. FFC will be required to arrange transport at its own expense and provide adequate insurance coverage for the goods while they are in transit.

(b) FFC uses a proprietary lacquer formula in its manufacturing process that improves the water resistance and shine of its outdoor furniture lines. FFC will sell CLC the exclusive Canadian rights to use this process.

(c) FFC’s customer support centre in Vancouver will continue to answer calls and emails from customers on assembly enquiries, missing parts, product information, and warranty claims for one year after the closing date of the sale. FFC will charge CLC a monthly fee for this service.

FFC will bill CLC’s head office in Alberta for each of the above items. The assets sold do not represent substantially all of the assets needed to run the furniture manufacturing business.

For each transaction, determine the place of supply.

Alex, Brook, and Charlene each began their own sole proprietorship

Alex, Brook, and Charlene each began their own sole proprietorship in a GST province on January 1, 20X4. The following chart summarizes their revenue for the first two years of activity:

Additional information:

• Alex sold a piece of capital property on May 15, 20X6 for $8,000.

• Brook always invoices his work on the 28th day of the month. His sales for each quarter were earned equally over each month of the quarter.

• Charlene is a licensed optometrist; 60% of her revenue consists of eye exams, while the remaining 40% consists of sales of eyeglasses and contact lenses.


For each individual, determine when small supplier status is lost, the date on which they are each required to be registered for GST, and the date on which each individual should begin charging GST.

Mr. Jones owns 100% of the commons shares of JL

Mr. Jones owns 100% of the commons shares of JL Corp, a CCPC engaged in an active business. The FMV of these shares is $900,000 and they have an ACB and PUC of $100,000. Mr. Jones wishes to crystalize his capital gains deduction (he has never previously had a capital gain) because he is concerned that a new government in the near future might bring an end to the capital gains deduction. Mr. Jones is thinking about two possible transactions to achieve this goal:

1. Mr. Jones will do a section 86 reorganization, and exchange his old common shares for preferred shares with an FMV of $900,000. The legal stated capital of the preferred shares will be $900,000.

2. Mr. Jones will do a section 85 transfer of his old common shares to JL Corp, electing an amount of $900,000, and receiving in exchange new common shares with an FMV of $900,000. The legal stated capital of the new common shares will be $100,000.


What are the tax consequences of these two transactions? Will they achieve Mr. Jones’s goal of crystallizing his capital gains deduction?

In addition to its active business income of $300,000, P

In addition to its active business income of $300,000, P Ltd., a CCPC, received dividends of $30,000 from a public and had a taxable capital gain of $90,000 on the sale of passive investments in 20X5. An allowable capital loss carry-over from a previous year of $20,000 was deducted in arriving at the corporation’s taxable income. Management anticipates that in 20X6, P will earn active business income of $450,000 and receive dividends from public corporations of $32,000. P is not associated with any other and has under $10 million of taxable capital. Income tax reference: ITA 125(1),(5.1),(7). Determine P’s anticipated small business deduction for the 20X6 taxation year. Assume the 20X6 taxation year begins after 2018.

Bob is a hobbyist photographer who has shot many weddings

Bob is a hobbyist photographer who has shot many weddings and engagement photos for friends and family over the years at no charge. He has been praised for his talents, but never seriously considered turning his passion into a business since he feels that wedding photography is extremely competitive.

After recently buying a new home, Bob got an idea to differentiate himself from other amateur photographers. Instead of photographing weddings, Bob will sell his services to real estate agents and provide photos, virtual tours, HD video walk-throughs, and other promotional materials to the agents for use in real estate listings. After doing some research, Bob is convinced there is a market for these services and he plans to officially launch his business on January 1, 20X1.

Most of Bob’s customers will be real estate agents who are GST registrants and entitled to recover GST on expenses via input tax credits (ITCs). However, Bob also anticipates that about 20% of his revenue will come from homeowners who are interested in selling their homes privately without the use of a real estate agent. These customers will be non-registrants and extremely price sensitive. To stay competitive, Bob will need to make any required GST inclusive in the pricing to these customers. For example, if Bob’s advertised price is $100 to a private homeowner, Bob will collect $100 plus zero GST if he is not a GST registrant or $95.24 plus $4.76 GST if he is a GST registrant.

Bob expects his revenue for the first year to be:

January–March, 20X1 ……………………….. $ 500
April–June, 20X1 ………………………………. 3,000
July–September, 20X1 ……………………… 6,000
October–December, 20X1 ……………… 12,000
Each subsequent quarter ………………. 15,000

To start his business, Bob will purchase new camera and video equipment for $13,000, as well as a new computer for $2,000 and a licence for photo-editing software for $400. He will need insurance coverage to operate and the annual premium is expected to be $2,800. Other operating expenses including office supplies will be approximately $1,500 for the year. These expenses are all exclusive of any applicable GST.


1. When is Bob required to register for GST? Is there any benefit to registering earlier?

2. Assuming Bob registers for GST effective January 1, 20X1, should he use the general method, quick method, or simplified ITC method to account for the GST? Calculate his net tax owing under each method and provide an overall recommendation. Be sure to highlight any additional filing requirements that result from your recommendation.

Assume the remittance rate is 3.6%.

Calculate net income for tax purposes for each of the

Calculate net income for tax purposes for each of the three taxpayers. Income tax reference: ITA 3.

Taxpayer A

Taxpayer B

Taxpayer C

Employment income


Business income (loss)


Property income (loss)


Pension income


Capital gain (loss)



Blakey’s Enterprises Ltd. is a Canadian-controlled private corporation that has

Blakey’s Enterprises Ltd. is a Canadian-controlled private that has operated a small retail men’s clothing store in rural Ontario for 70 years. Like his father before him, Charlie Blakey is a conservative businessman who believes that personal service and a choice of inventory is the key to success. In fact, he is so concerned with attempting to keep customers happy that he seldom holds after-season sales for fear of offending those customers in a small town who have paid the full retail price.

His banker often says, “Charlie, you’ve got to get that inventory down. You turn that stock only three times a year, which is much less than the norm for your industry.” Blakey knows this to be true but always says he would rather keep unsold stock after the end of season than unload it at a discount. His interest costs are understandably high, and during the last economic crisis, when interest rates reached an all-time high, he had some concern for the store’s survival.

Blakey’s daughter Kimberleigh also works in the business but has little interest in it. Most of her time is spent on a few administrative matters and outside business interests. There are four staff members on the payroll—Blakey, his daughter Kimberleigh, George (near retirement), and Fred. Their salaries are given below.

Blakey ………………………………………………………. $24,000
Kimberleigh, Blakey’s daughter ………………….. 16,000
George ………………………………………………………. 16,000
Fred …………………………………………………………… 20,000

Fred is the most enthusiastic of the group and is constantly coming up with new ideas, only to see them put aside by Blakey. As Blakey reaches retirement age, Fred approaches him with the idea of purchasing the business. After discussing the matter with his daughter, Blakey decides to sell the store to Fred provided that a reasonable price can be established and that Fred can raise the necessary cash to meet the full purchase price.

Blakey has provided Fred with the most recent (see Exhibits 1, 2, and 3) as well as the following information:

1. Profits during the recent recession were nominal, according to the past However, the most recent year was profitable, and in order to avoid an excessive tax burden, Blakey undervalued the closing inventory by $20,000. Blakey’s tax rate is 13%.

2. Blakey is satisfied that the current level of profits reflects future expectations and that the past year’s results, during the recession, should be ignored.

3. The outstanding shareholder’s loan is non–interest-bearing and is payable on demand.

4. For years, Blakey has obtained his personal clothes from the store without cost. The amount has varied from year to year; in the previous year the cost value of clothing taken was $4,000.

5. In addition, certain expenses have always been paid by the store. Blakey’s car is leased by the store at a cost of $380 per month and is used primarily to get him to and from work. From time to time, Blakey drives to Toronto on buying trips. The store also owns a four-wheel-drive Jeep used exclusively by Kimberleigh.

6. Travel expenses include a $1,200 trip to Ithaca, New York, for Blakey and his wife to attend a bowling tournament. Blakey’s great love is bowling, and his store annually gives away a fine suit as a prize for a bowling tournament, which is usually held in the United States.

7. Blakey’s daughter Kimberleigh will obtain another job before the sale. Fred does not intend to hire a replacement for her. Fred asks Blakey to remain on the staff after the sale for a salary of $24,000 per year. Fred will manage the store. (A friend of his, the local manager of a department-store men’s wear department, earns a salary of $30,000.)

8. The building and land had been acquired years ago for $47,000. The building has been depreciated to $15,000 since acquisition. A recent appraisal indicated that the property is now worth $90,000. The building has an area of 1,500 square feet. Space of similar quality is usually leased at $6 per square foot net of all building expenses and property taxes.

9. Published statistics indicate that stores of this nature are currently valued based on a normal after-tax return of 20%.

10. Fred is anxious to proceed because a national men’s wear chain has also approached Blakey to discuss a buy-out.


Assist Blakey and Fred in establishing a value for the business. Also, consider how this value may be affected if the purchaser is the clothing store chain, rather than Fred.