Budget 2024 proposed several amendments to the information gathering provisions in the Income Tax Act (the “Act”) intended to, as stated in the Supplementary Information regarding tax measures, “enhance the efficiency and effectiveness of tax audits and facilitate the…
Introduction
The Tax Court of Canada’s recent decision in Coopers Park Real Estate Development Corporation v His Majesty the King, 2024 TCC 122 (“Coopers Park”) serves as an important reminder of the unique and protected nature of privileged communications…
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…
Yesterday, the CRA announced it will not require bare trusts to file a T3 Income Tax and Information Return (including Schedule 15 Beneficial Ownership Information of a Trust) for their 2024 taxation year, unless the CRA directly requests such…
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…
