Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114 -- summary under Subsection 267.1(2)

By services, 17 May, 2024

GMCL (a car manufacturer) was the administrator of various defined benefit pension plan trusts for its employees. Royal Trust was the trustee. Desjardins JA found no reviewable error in the finding of the Tax Court that GMCL was not a trustee, so that s. 267.1 had no application to it.

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Excise Tax Act - s. 267.1(2)
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administrator of pension trust was not a trustee, and not subject to s. 267.1
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