Aug 7, 2008
Artistic Ideas Inc. v. The Queen
Irving Marks represented Artistic Ideas Inc., the promoter of a tax motivated charitable donation program. The Canada Revenue Agency (CRA) took the position that the fees earned by the promoter were subject to GST and that the documentation structuring the transaction so that no GST was applicable was a sham. After a lengthy trial in the Tax Court of Canada it was held that the documentation was valid, and that there was no GST payable on the promoter's fees.