Much has already been written about the proposed addition of section 237.4 to the federal Income Tax Act (“ITA”), which would impose mandatory reporting in respect of “notifiable transactions.” The purpose of this post is not to explain the notifiable…
Introduction
In 2017, the City of Vancouver introduced its annual residential vacancy tax (or “empty homes tax”). At that time, the tax rate was 1% of the assessed value of a subject property. The governing statute and administration program were…
Vacant housing taxes came into effect in Toronto and Ottawa for 2022, meaning that homeowners will have to file their first occupancy status declaration by February 2023 (for Toronto) and March 2023 (for Ottawa). Toronto’s portal is now open for…
The Court of Justice for the European Union (CJEU) recently invalidated a provision derived from the EU Directive informally known as DAC6 which requires lawyers to report their involvement in certain cross-border tax-planning arrangements to third parties. The provisions analyzed…
Khanna v. The Queen, 2022 FCA 84 is an important decision of the Federal Court of Appeal (the “FCA”) on the topic of gross-negligence penalties imposed under subsection 163(2) of the Income Tax Act (Canada) (the “Act”). The decision…
A loan or indebtedness which meets the following statutory requirements is generally referred to as a “prescribed rate loan”:
(a) interest is charged on the loan or indebtedness at a rate equal to or greater than the lesser…
The Prohibition on the Purchase of Residential Property by Non-Canadians Act (the “Act”) enters into force this Sunday (January 1, 2023). As supplemented by detailed regulations (the “Regulations”), the Act prohibits any “non-Canadian” from purchasing, directly or indirectly,…
On November 3, 2022, the Department of Finance released revised draft legislation proposing to implement the “excessive interest and financing expenses limitation” (EIFEL) rules first announced in Budget 2021. Initial draft legislation was released on February 4, 2022 and…
On November 4, 2022, Bill C-32 (44-1) was tabled in the House of Commons. Among other things, that Bill contains the latest version of the proposed enhanced trust reporting rules and stipulates that they would be effective for trusts’…
The Federal Government has announced that the Fall Economic Statement 2022 will be presented in the House of Commons on November 3, 2022 at approximately 4:00 p.m. ET.
The Federal Government’s 2022 Budget stated that the Fall Economic…
