I am willing to consider any engagement involving GST and customs issues. However, most of my practice has evolved into the two areas described below along with examples of resent engagements.

Foreign businesses beginning to export goods or services to Canada

  • Determining whether goods qualify for duty-free treatment under the USMCA (successor to NAFTA) Rules of Origin, or whether the goods need not qualify if they are duty-free under the general Customs Tariff.

  • Determining whether a foreign corporation providing services in Canada is carrying on business in Canada and therefore required to register for GST purposes.

  • Determining whether a foreign corporation may register voluntarily for GST and, if so, whether that is advisable.

  • Recovery of GST paid by an unregistered non-resident on the importation of goods into Canada.

  • Application of the GST “drop shipment rules” to a machine purchased in Canada by a foreign corporation for the use by a Canadian corporation in manufacturing goods on behalf of the foreign corporation.

Real property transactions (GST/HST)

  • Sale of a multi-use rural acreage property.

  • Sale or change-in-use of a residential property that has been used for short-term rentals (often through AirBnB or VRBO).

  • Distribution of real property from an estate.