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 June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…
Section 160 of the Income Tax Act (Canada) (the Act) is a collection tool that the Canada Revenue Agency (CRA) may use to collect unpaid tax debts of a taxpayer from third parties. This provision applies where a tax debtor…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…
The Ontario Ministry of Government and Consumer Services launched its much-anticipated Ontario Business Registry online today. Organizations that are incorporated, registered or licensed to carry on business in Ontario can now directly access over 90 services 24/7 all-year-round, and will be…
On October 8, 2021, the Organisation for Economic Cooperation and Development (OECD) announced that 136 countries, including Canada, reached an agreement to address tax challenges related to multinational enterprises (MNEs) and the digitalization and globalization of the economy.
The…
On July 15, 2021, Toronto City Council approved a plan for implementing a new tax on the city’s vacant homes beginning in 2022. The proposed tax appears to be very similar to the “empty homes tax” already in force in…
In Bresse Syndics Inc. v. The Queen, 2021 FCA 115 (sub nom. CO2 Solution Technologies Inc.), the Federal Court of Appeal (“FCA”) considered the extent to which a public corporation (“Pubco”) held de facto control over a corporation (the…
In Brent Carlson Family Trust v. Canada (National Revenue), 2021 FC 506, two family trusts made requests to amend elections for the 2014 taxation year filed under subsection 85(1) of the Income Tax Act (Canada) (the “Act”) in respect…
