Overview: the changing sales tax landscape
The Canadian sales tax landscape has undergone a substantial transformation in recent years. The mechanical tax issues facing businesses in the 1990s have for the most part been resolved. New highly technical issues driven by sensitive policy considerations now occupy this space.
The challenge for tax professionals has been compounded by a marked increase both in the speed at which business is performed and in the complexity of business transactions.
Ironically, during this same period the standard of care expected of private industry tax professionals has also increased.
Challenges
1. Identification of options: Businesses need to ensure that they are being presented with the full complement of options prior to proceeding down a course of action. Reliance solely upon tax materials may result in missed opportunities. Unfortunately, options are increasingly difficult to identify because they originate from so many diverse sources.
2. Understanding the framework in which tax law operates: Tax provisions were never intended to be interpreted in a vacuum. Challenging (and complying with) tax legislation is simplified when the object and purpose of the legislation is fully understood. Technical positions which are inconsistent with the legislative scheme are highly likely to fail.
3. Managing the information: proliferation of information places an extremely high burden on businesses. Identification and extraction of the most critical information requires an extremely high level of commitment and skill.
4. Understand your sources of leverage: Understanding your sources of leverage and the means by which leverage may be enhanced is fundamental both to the tax planning and to the dispute resolution processes. Leverage analysis requires a sound examination of your position both from a technical and from a practical perspective.
5. Selection of the optimal course of action: Balancing competing interests and weighing off options are two of the most significant current challenges. 
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