On December 3, 2021, a unanimous Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51). In doing so, the Court held that capital contributions and corporate oversight are not relevant…
Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…
Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
In Canada (National Revenue) v. Boguski, 2021 FCA 118 affirming 2018 TCC 236, the Federal Court of Appeal (the “FCA”) affirmed the decision of the Tax Court of Canada (the “Tax Court”) to dismiss the Minister’s application for an…
The Federal Court of Appeal (the “FCA”) recently released its highly anticipated decision in Canada v. Deans Knight Income Corporation, 2021 FCA 160. The case represents the FCA’s first consideration of an alleged abuse of the “control” threshold for…
On December 16, 2021, the Office of the Prime Minister issued a mandate letter to the Deputy Prime Minister and Minister of Finance, Chrystia Freeland. The letter asked that steps be taken to establish or strengthen programs addressing public…
In a unanimous decision, the Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51), holding that Loblaw Financial was entitled to rely on the financial institution exception set out in…
On November 25, 2021, the Honourable Eugene P. Rossiter provided an update on behalf of the Tax Court of Canada at the Canadian Tax Foundation’s 73rd Annual Tax Conference.
The Chief Justice commented on administrative matters at the Court and…
On November 24, 2021, the Federal Government introduced Bill C-2 in Parliament to implement previously announced COVID-19 economic response measures aimed at industries and areas that may be particularly hard-hit by the pandemic’s lingering economic effects. This reflects a…
The Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L.(2021 SCC 49). The Court concluded that the Minister of National Revenue did not discharge her burden of proving abusive tax avoidance in…
