GST/HST Deemed Trust: Potential Harsh Consequences For Secured Lenders

On July 2, 2026, the Canada Revenue Agency (CRA) published its updated Guidance on the Common Reporting Standard (Updated CRS Guidance).

The Federal Court has approved an $8.7 million class action settlement in Sweet v. His Majesty the King (2026 FC 590), resolving claims from the 2020 credential-stuffing cyberattacks on Government of Canada online accounts accessed via GCKey, including CRA My Account.

When a specified motor vehicle is acquired through a private sale (for instance, from an individual who is not registered for GST/HST purposes), the transaction is generally not subject to GST/HST.

The GST/HST New Housing Rebate lets a purchaser recover part of the GST/HST paid on a newly built or substantially renovated home used as a primary residence.

Canada's new Productivity Mega Deduction promises to slash the marginal effective tax rate on business investment to just 6.4%, positioning the country as the most competitive G7 nation for capital deployment. This permanent tax incentive extends immediate expensing to roughly 65% of capital assets, fundamentally reshaping the economics of investing in Canadian operations across manufacturing, energy, technology, and resource sectors.

The Canada Revenue Agency has announced a new priority system for advance income tax ruling requests, targeting investments of at least $1 billion in Canada. This initiative aims to accelerate the tax certainty process for major investors by reducing processing times and providing binding guidance on how specific Income Tax Act provisions apply to proposed transactions.

The Canada Revenue Agency has announced a new policy to prioritize advance income tax ruling requests for investments of $1 billion or more in Canada. This initiative aims to provide greater tax certainty and reduce risks for major investors, potentially accelerating large-scale project development and strengthening Canada's economic competitiveness. However, questions remain about implementation timelines and potential impacts on smaller ruling requests.

When the Canada Revenue Agency (CRA) concludes that a GST/HST registrant’s books and records do not provide a complete or reliable picture of its taxable sales, it may reconstruct those sales using an alternative or indirect audit method.

If you have signed, or are about to sign, an agreement to buy a newly built home in Ontario, the HST you recover could be anything from nothing to $130,000. The difference usually comes down to a signing date, a price threshold, or whose name is on the purchase agreement, and not to whether you are buying your first home.

Canada's new Productivity Mega Deduction permanently provides immediate expensing for a wide range of depreciable property and Canadian development expenses, dramatically expanding the scope beyond the previously announced Productivity Super Deduction. The measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4%, positioning it as the lowest among major economies and less than half the U.S. rate.