The British Columbia Supreme Court recently clarified the definition of “non-qualifying activity” under subsection 90(1) of the Provincial Sales Tax Exemption and Refund Regulation, BC Reg 97/2013 (the “PSTERR”) in Tolko Industries Ltd. v. British Columbia 2024 BCSC…
Yesterday (April 16, 2024), the Department of Finance Canada published its 2024 federal budget (“Budget 2024”). Several major tax proposals were announced. This blog post briefly outlines those relating to income tax.
1. Increased Capital Gains Inclusion Rate …
Filing a notice of objection is the first step a taxpayer must take to dispute an assessment or reassessment issued by the Minister of National Revenue (the “Minister”). Failure to follow the proper procedural rules for filing an objection can…
BC announced several proposed tax measures in its 2024 budget (released on February 22, 2024). Included in the long list of proposed changes – the more notable of which were summarized in our recent Tax Alert – are…
The Federal Court of Appeal (the “FCA”) recently released its decision in 3295940 Canada Inc v His Majesty The King, 2024 FCA 42. This decision is a welcome development in the jurisprudence regarding the application of the General Anti-Avoidance…
Subsection 215(1) of the Income Tax Act (the “Act”) imposes on Canadian tenants the obligation to withhold and remit Part XIII tax on residential rent paid to non-resident landlords. The applicable tax rate is 25% of the gross rent paid,…
On June 20, 2024, Bill C-59 and Bill C-69 each received Royal Assent. Together, they make sweeping changes to the federal Income Tax Act (the “Act”) that taxpayers and their advisors simply must know. The below chart notes…
Yesterday, the Canada Revenue Agency (“CRA”) announced that, in its view, the construction of purpose-built rental housing (“PBRH”) for purposes of the PBRH rebate under the Excise Tax Act is generally “considered to begin at the time the excavation…
Yesterday, the Tax Court of Canada released its decision in DAC Investment Holdings Inc. v R. Led by Matthew Williams, Florence Sauve, and Brittany Rossler, the decision represents a major win for taxpayers across the country.
In…
The B.C. government tabled legislation yesterday which would introduce its proposed “home flipping tax”. First announced in the province’s 2024 budget (and discussed in greater detail in our previous blog post), the draft legislation was contained in Bill…
