1351231 Ontario Inc. v. His Majesty the King
1351231 Ontario Inc.
His Majesty the King
Law Firm / Organization
Department of Justice Canada
Lawyer(s)

Robert A. Zsigo

- Parties: The appellant was 1351231 Ontario Inc. The respondent was His Majesty the King. 

- Subject Matter: This appeal challenged a judgment of a trial judge of the Tax Court of Canada. The judgment dismissed an appeal against a notice of assessment issued by the Minister of National Revenue under Part IX of the Excise Tax Act, 1985 (ETA). The judgment found that the appellant's sale of an Ottawa-based condominium unit was a taxable supply of real property subject to goods and service tax/harmonized sale tax (HST). The appeal alleged that the judgment erred in fact and law in concluding that the sale was a taxable supply of real property, that the sale was not an exempt supply under s. 2 of Part I of Schedule V of the ETA, that the condominium was not a “residential complex” at the time of sale under s. 123 (1) of the ETA. This case is ongoing. 

- Date: The hearing was set on Mar. 4, 2025. 

- Venue: This was a federal case before the Federal Court of Appeal. 

- Amount: No financial award was specified. 

Federal Court of Appeal
A-141-24
Taxation
$ 0
15 April 2024