Overview
The Tax Court of Canada Rules (General Procedure) provide that a party may be entitled to substantial indemnity costs if the party makes a settlement offer and ends up obtaining an outcome at trial as favourable as or…
Overview
Tax disputes generally hinge on whether the imposition of taxes and penalties is correct. However, there are situations where a taxpayer can be granted relief from the imposition of penalties and/or interest even if they were correctly levied. Subsection…
The Canada Revenue Agency (the “CRA”) is granted significant powers to gather information from persons under the Income Tax Act (Canada) (the “ITA”) and the Excise Tax Act (Canada) the (“ETA”), including the right to acquire and inspect documentation, enter…
In the recent decision of Canada (National Revenue) v. Shopify Inc., 2025 FC 969 (“Shopify”), the Federal Court refused to authorize the Canada Revenue Agency (the “CRA”) to issue a so-called “unnamed person requirement” (“UPR”) to Shopify Inc. (the…
In Seabridge Gold Inc. v British Columbia, 2025 BCSC 558, a recent case argued by Thorsteinssons LLP, the British Columbia Supreme Court held that expenses incurred to assess the economic viability of a mineral resource are eligible for the…
Introduction
On March 26, 2025, the Tax Court of Canada (“TCC”) issued its decision in MEGlobal Canada ULC v. HMK. Following the recent decision of the Supreme Court of Canada (“SCC”) in Dow Chemical Canada ULC v. Canada.,…
The BC Court of Appeal and the BC Supreme Court have issued two recent judgments regarding the application of the additional property transfer tax (“ATT”), commonly called the BC foreign buyers tax, imposed under the Property Transfer Tax Act, RSBC…
On June 20, 2024, Bill C-69 received Royal Assent. As previously discussed, that Bill made several amendments to the federal Income Tax Act (the “Act”) including the introduction of section 67.7. In furtherance of the Bill’s stated intention…
On Friday, in the face of mounting pressure – including a court application launched by Thorsteinssons LLP – the Department of Finance (Finance) announced that the implementation date for the proposed capital gains inclusion rate changes would be…
Yesterday, Thorsteinssons LLP (Canada’s largest tax law firm) launched a comprehensive challenge in Federal Court to the Canada Revenue Agency’s proposed enforcement of the capital gains tax hike. Led by David Davies, Alexander Demner, Florence Sauve, and…